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.
- 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
- Dividends
- Interest
- Royalties
- 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
- Capital
- Exemption Method
- Credit Method/Relief from Double Taxation
- Non-Discrimination
- Mutual Agreement Procedure
- Exchange of Information/Exchange of Information and Administrative Assistance
- Members of Diplomatic Missions and Consular Posts
- Territorial Extension
- Entry into Force
- Termination