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Vol 23 No 6 June/July 2018

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This book is now Out of Print.
A new edition has been published, the details can be seen here:
Klaus Vogel On Double Taxation Conventions 4th ed isbn 9789041122988

Klaus Vogel On Double Taxation Conventions 3rd ed

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ISBN13: 9789041108920
ISBN: 9041108920
New Edition ISBN: 9789041122988
Published: November 1997
Publisher: Kluwer Law International
Country of Publication: The Netherlands
Format: Hardcover
Price: Out of print

Full Title: Klaus Vogel on Double Taxation Conventions, Third Edition, A Commentary to the OECD, UN and U.S. Model Conventions for the Avoidance of Double Taxation of Income and Capital, With Particular Reference to German Treaty Practice

Double taxation conventions (DTCs) raise a plethora of interpretational questions for the practitioner and student of tax law. This book provides the answers.

An encyclopedic treatise on DTCs, Klaus Vogel on Double Taxation Conventions is a guide to all legal issues DTCs raise and includes information on worldwide case law and commentators' views. The OECD Model Convention serves as the organisational basis for this work. Each chapter focuses on one article of the Convention and provides: the wording of the article and that of the respective articles of the UN and US Models, the official Commentary by OECD, and an extensive discussion by the authors of the legal problems involved.

In addition, Klaus Vogel on Double Taxation Conventions offers an account of all German tax treaties, how they differ from the model provisions, and the potential practical impact of such differences.

The first two editions have been used by lawyers, tax advisers, and scholars all over the world. Courts in Canada, Germany, South Africa, and the Netherlands have cited them as authority. This revised edition includes the most recent OECD Model revisions and all recent case law and relevant literature. The authors have rethought many of the problems discussed, further improved their argument, and amended their views where they have been convinced by opponents

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Persons Covered
Taxes Covered
General Definitions
Permanent Establishment
Income from Immovable/Real Property
Business Profits
Shipping, Inland Waterways Transport and Air Transport
Associated Enterprises. Preface to Articles 10 to 12
Capital Gains
Independent Personal Services
Dependent Personal Services
Directors' Fees/Directors' Fees and Remuneration of Top Level Managerial Officials
Artistes and Sportsmen/Income Earned by Entertainers and Athletes
Pensions/Pensions and Social Security Payments/Pensions, Annuities, Alimony, and Child Support. Art
Government Services/Remuneration and Pensions in Respect of Government Services
Students/Payments Received by Students and Apprentices/Students and Trainees
Other Income
Exemption Method
Credit Method/Relief from Double Taxation
Mutual Agreement Procedure
Exchange of Information/Exchange of Information and Administrative Assistance
Members of Diplomatic Missions and Consular Posts
Territorial Extension
Entry into Force