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Practice Area: International Taxation

Photo of the title: Klaus Vogel on Double Taxation Conventions, Third Edition - 9041108920 - 9789041108920




Klaus Vogel on Double Taxation Conventions, Third Edition
by: Klaus Vogel
November 1997,  ISBN 9041108920
ISBN 13: 9789041108920
1728 pp. Hardcover
Add to Shopping Cart: Klaus Vogel on Double Taxation Conventions, Third Edition - 9041108920 - 9789041108920 USD price: $757.00
          




Add to Shopping Cart: Klaus Vogel on Double Taxation Conventions, Third Edition - 9041108920 - 9789041108920
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.




  1. Persons Covered
  2. Taxes Covered
  3. General Definitions
  4. Permanent Establishment
  5. Income from Immovable/Real Property
  6. Business Profits
  7. Shipping, Inland Waterways Transport and Air Transport
  8. Associated Enterprises. Preface to Articles 10 to 12
  9. Dividends
  10. Interest
  11. Royalties
  12. Capital Gains
  13. Independent Personal Services
  14. Dependent Personal Services
  15. Directors' Fees/Directors' Fees and Remuneration of Top Level Managerial Officials
  16. Artistes and Sportsmen/Income Earned by Entertainers and Athletes
  17. Pensions/Pensions and Social Security Payments/Pensions, Annuities, Alimony, and Child Support. Art
  18. Government Services/Remuneration and Pensions in Respect of Government Services
  19. Students/Payments Received by Students and Apprentices/Students and Trainees
  20. Other Income
  21. Capital
  22. Exemption Method
  23. Credit Method/Relief from Double Taxation
  24. Non-Discrimination
  25. Mutual Agreement Procedure
  26. Exchange of Information/Exchange of Information and Administrative Assistance
  27. Members of Diplomatic Missions and Consular Posts
  28. Territorial Extension
  29. Entry into Force
  30. Termination




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