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This publication (in three volumes) aims at providing students of International, Transfer Pricing and EU tax law and those who practice in these areas of law, with the most important basic texts.
Volume A focuses on international tax law materials. On the basis of the 2014 version of the OECD Model Convention comparisons are included with the 1963 OECD Draft Convention, the 2011 UN Model and the 2016 US Model.
The OECD Model itself, the introduction to this Model and the OECD Commentary are presented in a way in which the successive changes, additions and deletions that were made to the 1977 text in 1992, 1994, 1995, 1997, 2000, 2003, 2005, 2008, 2010 and 2014 can be readily identified. The first volume also includes the current UN Commentary.
In addition to these Model and Commentary texts, various OECD discussion drafts with proposed changes to the OECD Model and/or Commentary have been included, along with a series of OECD reports: the 1999 Partnership Report, the 2010 Report on the attribution of profits to PEs and the current version of the Transfer Pricing Guidelines.
This year the two – for tax treaties – most important Final BEPS Action Reports of October 2015 (Action 6: Treaty Abuse and Action 7: Artificial Avoidance of PE) have been included along with two additional BEPS Discussion Drafts of July 2016 (Action 7: Attribution of profits to Agency PE and Action 8-10: Revised guidance to profit splits).
Volume B (Publication Abandoned) includes the most relevant texts with regard to transfer pricing – an area of rapid growing interest. In addition to a comprehensive series of OECD documents (including, of course, the updated Transfer Pricing Guidelines and updating discussion drafts), this volume also covers the UN Practical Manual on Transfer Pricing for Developing Countries (2013), various EU documents (including reports of the Joint Transfer Pricing Forum) and the US Regulations on Sec. 482.
Volume C (Publication Abandoned) contains EU texts. In addition to the full text of the Treaty on the Functioning of the European Union itself, the updated texts of the various Directives are included – many of them in English, French and German. Also, over 200 decisions of the EU Court of Justice (virtually all in English) are reproduced along with the Opinions of the Advocate General in cases where no ECJ decision is available yet, all dealing with income tax issues or directly related thereto.
This 16th edition includes brief surveys of the tax systems of 29 countries.