Wildy logo
(020) 7242 5778

Wildy’s Book News

Book News cover photo

Vol 22 No 3 March/April 2017

Book of the Month

Cover of Company Directors: Duties, Liabilities and Remedies

Company Directors: Duties, Liabilities and Remedies

Edited by: Simon Mortimore
Price: £225.00

Pupillage & Student Offers

Special Discounts for Pupils, Newly Called & Students

Read More ...

Secondhand & Out of Print

Browse Secondhand Online


UK Public Holiday May 2017

Wildy's will be closed on Monday 1st May and will re-open on Tuesday 2nd May.

Online book orders received during the time we are closed will be processed as soon as possible once we re-open on Tuesday.

As usual Credit Cards will not be charged until the order is processed and ready to despatch.

Any non-UK eBook orders placed after 5pm on the Friday 28th April will not be processed until Tuesday 2nd May. UK eBook orders will be processed as normal.

Hide this message

Judicial Interpretation of Tax Treaties: The Use of the OECD Commentary

ISBN13: 9781785365874
Published: October 2016
Publisher: Edward Elgar Publishing Limited
Country of Publication: UK
Format: Hardback
Price: £195.00

Low stock.

Judicial Interpretation of Tax Treaties is a detailed, comprehensive analytical guide to the interpretation of tax treaties at the national level. The book focuses on how domestic courts interpret and apply the OECD Commentary to the OECD Model Tax Convention on Income and on Capital.

Adopting a global perspective, the book gives a systematic presentation of the main interpretive proposals put forward by the OECD Commentary, and analyses selected cases decided in domestic tax systems in order to assess whether and how such solutions are adopted through national judicial process, and indeed which of these are of most practical value.

The book operates on two levels: Firstly it sets out a clear and comprehensive framework of tax treaty law, which will be an important tool for any tax practitioner. Secondly, the book provides crucial guidance on issues of tax treaty law as applied at domestic level, such as investment or business income, dispute resolution and administrative cooperation.

Key features:

  • A detailed and structured introduction to the main issues of tax treaties
  • Ideal for practitioners requiring a grounding in the functioning of tax treaty law
  • Concise summaries of the relevant issues, cases, and problems for each discrete chapter
  • Offers a basic ‘globalized’ handbook that is missing in the current literature about judicial application of tax treaties.
This comprehensive treatment of tax treaty law is a ready reference for tax practitioners, and an essential introduction for non-specialists. The book can also be used as a companion to courses in international taxation.

1. Scope of the Treaties
2. Residence for Treaty Purposes
3. Definition of Permanent Establishment
4. Business Profits and Associated Enterprises
5. Income from Immovable Property, Capital Gains, and Capital
6. Income from Equity and from Debt
7. Royalties
8. Income from Employment, Directors’ Fees, and Students
9. Entertainers and Sportspersons
10. Pensions and Government Service
11. Other Income and International Transport
12. Methods for Elimination of Double Taxation
13. Non-Discrimination
14. Mutual Agreement Procedure
15. Exchange of Information and Assistance in Collection