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Double taxation conventions are playing an increasingly major role in the tax world. The OECD Model Double Taxation Convention is used as the basis for most of the world's double taxation treaties. The UK has now almost 100 agreements with other countries and the vast majority of international trade and investment is now governed by such agreements rather than by general law.
This second edition has been updated to include the text of the 1992 OECD Model Tax Convention (in both English and French) which replaced the 1977 Model, along with the official OECD commentary. This work begins with an introduction to international tax conventions, focusing on interpretation and operation in practice. The scope of the introductory topics has been expanded to cover areas such as State Succession, EC law and procedural issues.
Philip Baker deals thoroughly with the interpretation of each article of the Model Convention, bringing in and discussing cases which have been decided in jurisdictions around the world. He also discusses the changes from the 1977 Model. This book is designed to guide those who have to interpret and apply tax treaties. It is also of relevance to practitioners in all jurisdictions who are presented with problems in the application of tax treaties.