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Klaus Vogel On Double Taxation Conventions 5th ed

Edited by: Ekkenhart Reimer, Alexander Rust

ISBN13: 9789403513003
Previous Edition ISBN: 9789041122988
Published: January 2022
Publisher: Kluwer Law International
Country of Publication: The Netherlands
Format: Hardback, 2 volumes
Price: £400.00

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Klaus Vogel on Double Taxation Conventions is regarded as the international gold standard on the law of tax treaties. This article-by-article commentary has been completely revised and updated to give you a full and current account of double tax conventions (DTCs).

DTCs form the backbone of international taxation, but they raise many interpretational questions. This market leading work will provide you with the answers. Based on the OECD/G20 Multilateral Instrument, the OECD MC and Commentary published in 2017 and the most recent amendments to the UN MC, the book also includes relevant case law and scholarly literature upto and including 2020.

Previous editions of the Vogel have been routinely relied on by courts around the world (including Australia, Canada, Germany, India, South Africa, the Netherlands and United Kingdom).

What’s new in this edition?

There have been many important developments in this area since the last edition in 2015. The authors discuss these developments and the effect they will have upon practitioners working in this area. They also provide a wealth of new and revised case law, along with the DTCs of emerging countries.

You’ll find:

Reports about major features in the DTC practice of many leading jurisdictions, such as:

  • the DTC practice of Austria, Canada, France, Germany, India, the Netherlands, Switzerland, the UK and the US
  • Sections on divergent country practice covering their national models and networks of bilateral DTCs
  • Thorough analysis of the OECD and UN model, as well as the implementation of these models in practice
  • Amendments of bilateral DTCs, textual or in substance, on the basis of the 2017 Anti-BEPS Multilateral Instrument
  • Coverage of a full range of the latest tax treaties around the world, including important treaties between OECD and BRICS countries

This new Fifth Edition of Klaus Vogel on Double Taxation Conventions continues to reflect the unchallenged role of the OECD. The OECD MC, accompanied by the official Commentary, guidelines, reports and other recommendations, has sustained its position as the most important legal instrument in the area of DTCs. On occasion, the UN MC and Commentary diverge from the OECD texts. When this happens, the authors deal with the specifics of the UN MC in separate annotations and analyses, explaining and making sure you understand the differences.

How this will help you:

  • All the information you need to confidently advise on issues such as the taxation of income, taxation of capital and the elimination of double taxation
  • Know that your advice to clients is based on the most up-to-date and respected information available, from an outstanding team of editors and authors

The editors, Professors Ekkehart Reimer and Alexander Rust, have worked with the late Professor Vogel as well as an international team of top experts to completely update and enhance the content.

Volume I
List of Abbreviations
Chapter I. Scope of the Convention
Article 1. Persons Covered
Article 2. Taxes Covered
Chapter II. Definitions
Article 3. General Definitions
Article 4. Resident
Article 5. Permanent Establishment
Chapter III. Taxation of Income
Article 6. Income from Immovable Property
Article 7. Business Profits
Article 8. International Shipping and Air Transport
Article 9. Associated Enterprises
Preface to Articles 10 to 12
Article 10. Dividends
Article 11. Interest
Article 12. Income from Royalties
Article 13. Capital Gains
Ex-Article 14. Independent Personal Services

Volume II
Article 15. Income from Employment
Article 16. Directors’ Fees/Directors’ Fees and Remuneration of Top-Managerial Officials
Article 17. Entertainers and Sportspersons
Article 18. Pensions
Article 19. Government Service
Article 20. Students
Article 21. Other Income
Chapter IV. Taxation of Capital
Article 22. Capital
Chapter V. Methods for Elimination of Double Taxation
Article 23A/23B: Exemption Method/Credit Method
Chapter VI. Special Provisions
Article 24. Non-discrimination
Article 25. Mutual Agreement Procedure
Article 26. Exchange of Information
Article 27. Assistance in the Collection of Taxes
Article 28. Members of Diplomatic Missions and Consular Posts
Article 29. Entitlement to Benefits
Article 30. Territorial Extension
Chapter VII. Final Provisions
Articles 31/32. Entry into Force/Termination