Klaus Vogel on Double Taxation Conventions, Third Edition / Edition 3

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Overview

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.

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Product Details

  • ISBN-13: 9789041108920
  • Publisher: Wolters Kluwer Law & Business
  • Publication date: 11/1/1997
  • Edition description: Subsequent
  • Edition number: 3
  • Pages: 1520
  • Product dimensions: 6.64 (w) x 9.70 (h) x 3.08 (d)

Table of Contents

List of abbreviations
Introduction 2
Title of the Convention 77
Ch. I Scope of the Convention
Art. 1 Persons Covered 83
Art. 2 Taxes Covered 137
Ch. II Definitions
Art. 3 General Definitions 165
Art. 4 Resident-Residence 218
Art. 5 Permanent Establishment 271
Ch. III Taxation of Income
Art. 6 Income from Immovable/Real Property 366
Art. 7 Business Profits 391
Art. 8 Shipping, Inland Waterways Transport and Air Transport 475
Art. 9 Associated Enterprises 510
Art. 10 Dividends 575
Art. 11 Interest 706
Art. 12 Royalties 765
Art. 13 Capital Gains 810
Art. 14 Independent Personal Services 853
Art. 15 Dependent Personal Services 879
Art. 16 Directors' Fees/Directors' Fees and Remuneration of Top Level Managerial Officials 953
Art. 17 Artistes and Sportsmen/Income earned by Entertainers and Athletes 965
Art. 18 Pensions/Pensions and Social Security Payments/Pensions, Annuities, Alimony, and Child Support 997
Art. 19 Government Service 1018
Art. 20 Students/Payments Received by Students and Apprentices/Students and Trainees 1055
Art. 21 Other Income 1067
Ch. IV Taxation of Capital
Art. 22 Capital 1087
Ch. V Methods for Elimination of Double Taxation
Art. 23 A Exemption Method 1118
Art. 23 B Credit Method/Relief from Double Taxation 1119
Ch. VI Special Provisions
Art. 24 Non-Discrimination 1273
Art. 25 Mutual Agreement Procedure 1339
Art. 26 Exchange of Information/Exchange of Information and Administrative Assistance 1393
Art. 27 Members of Diplomatic Missions and Consular Posts 1453
Art. 28 Territorial Extension 1471
Ch. VII Final Provisions
Art. 29 Entry into Force 1476
Art. 30 Termination 1477
Annex I Review of German DTCs 1495
Annex II OECD Model Tax Convention on Income and on Capital 1995 1504
Annex III: 1. US Model Income Tax Convention 1996 1521
Annex III: 2. Technical Explanation 1543
Index 1629
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