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.
The first volume 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 2006 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. This volume also includes the ASEAN and Dutch Model income tax treaties.
In addition to these Model 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 (including the 1999 Partnership Report and the 2010-2013 version of the Transfer Pricing Guidelines). Further, as an illustration of how actual treaties look like, the texts of the US treaties with Canada, Germany and the UK, and the UK treaty with Germany are reproduced. Finally, tables in the inside of the front and back covers provide the withholding tax rates on crossborder dividends, interest and royalties as laid down in some 300 tax treaties.
The second volume 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 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.
The third volume contains EU texts. In addition to the full text of the Treaty on the Functioning of the European Union itself, the texts of the various Directives are included – many of them in English, French and German. Also, over 250 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 EU CoJ decision is available yet, all dealing with income tax issues or directly related thereto.
This 14th edition includes brief overviews of the tax systems of 28 countries.
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