A Global Analysis of Tax Treaty Disputes

A Global Analysis of Tax Treaty Disputes

by Eduardo Baistrocchi

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Overview

A Global Analysis of Tax Treaty Disputes by Eduardo Baistrocchi

This two-volume set offers an in-depth analysis of the leading tax treaty disputes in the G20 and beyond within the first century of international tax law. Including country-by-country and thematic analyses, the study is structured around a novel global taxonomy of tax treaty disputes and includes an unprecedented dataset with over 1500 leading tax treaty cases. By adopting a contextual approach the local expertise of the contributors allows for a thorough and transparent analysis. This set is an important reference tool for anyone implementing or studying international tax regulations and will facilitate the work of courts, tax administrations and practitioners around the world. It is designed to complement model conventions such as the OECD Model Tax Convention on Income and on Capital. Together with Resolving Transfer Pricing Disputes (2012), it is a comprehensive addition to current debate on the international tax law regime.

Product Details

ISBN-13: 9781108150170
Publisher: Cambridge University Press
Publication date: 08/17/2017
Series: Cambridge Tax Law Series
Sold by: Barnes & Noble
Format: NOOK Book
File size: 8 MB

About the Author

Eduardo Baistrocchi is Associate Professor of Law at the London School of Economics and Political Science (LSE). He studied law at the Universidad de Buenos Aires before obtaining an L.L.M. at Harvard Law School and later an L.L.M. on Tax Law at LSE. He has been a Fulbright Scholar and a Chevening Scholar. He has also been a Distinguished Visiting Professor in Brazil (FGV Direito Sao Paulo), Canada (University of Toronto) and the United States (Northwestern University). His research and publications are focused on international taxation, with a particular emphasis on tax treaty disputes in the G20. He applies interdisciplinary approaches, such as game theory and public choice, to investigate how the international tax regime operates. He has published in leading journals and publishing houses such as the British Tax Review, the Global Tax Treaty Commentaries, the Modern Law Review, the Oxford Journal of Legal Studies (OJLS) and Cambridge University Press.

Table of Contents

Volume 1. OECD Countries: Acknowledgements; List of contributors; List of tables and charts; List of cases; The golden bridge - analytical table of cases by pattern of dispute; Part I. The Context of Tax Treaty Disputes: 1. Introduction Eduardo Baistrocchi; Part II. OECD Countries: 2. Tax treaty disputes in the United States Yariv Brauner; 3. Tax treaty disputes in Australia Micah Burch; 4. Tax treaty disputes in Canada Arthur J. Cockfield; 5. Tax treaty disputes in Chile Ricardo Escobar and Mirenchu Muñoz; 6. Tax disputes and the European Union Arbitration Convention Georg Kofler; 7. Tax treaty disputes in France Jérôme Monsenego; 8. Tax treaty disputes in Germany Werner Haslehner; 9. Tax treaty disputes in Ireland Emer Hunt; 10. Tax treaty disputes in Italy Carlo Garbarino; 11. Tax treaty disputes in Japan Toshio Miyatake; 12. Tax treaty disputes in Mexico Oscar Echenique Quintana and Jorge E. Correa Cervera; 13. Tax treaty disputes in The Netherlands Kees van Raad, Hans Muste and Frank Pötgens; 14. Tax treaty disputes in South Korea Chang Hee Lee and Sunyoung Kim; 15. Tax treaty disputes in Switzerland Robert J. Danon; 16. Tax treaty disputes in Turkey Billur Yalti; 17. Tax treaty disputes in the United Kingdom Timothy Lyons and Jason Whiston. Volume 2. BRICS Countries and Beyond: 1. Introduction Eduardo Baistrocchi; Part III. BRICS Countries: 2. Tax treaty disputes in China Yongjun Peter Ni; 3. Tax treaty disputes in Hong Kong Michael Littlewood; 4. Tax treaty disputes in Brazil Isabel Calich and Joao Dacio Rolim; 5. Tax treaty disputes in Russia Irina Dmitrieva; 6. Tax treaty disputes in India Aseem Chawla; 7. Tax treaty disputes in South Africa Ernie Lai King; Part IV. Countries beyond the OECD and BRICS: 8. Tax treaty disputes in Argentina Manuel M. Benites; 9. Tax treaty disputes in Cyprus Christiana HJI Panayi and Margarita Liasi; 10. Tax treaty disputes in Uganda Annet Wanyana Oguttu; 11. Tax treaty disputes in Indonesia Freddy Karyadi and Darussalam; 12. Tax treaty disputes in Saudi Arabia Ehtisham Ahmad and Fahad Al-Kharashi; 13. Tax treaty disputes in Singapore Stephen Phua and Chai Sui Fun; Part V. Conclusion: 14. Patterns of tax treaty disputes: a global taxonomy Eduardo Baistrocchi; 15. Resolving tax treaty disputes: the global evolutionary path Eduardo Baistrocchi; 16. Triple non-taxation and BEPS: global implications Jinyan Li; 17. Tax treaty disputes: a global quantitative analysis Eduardo Baistrocchi and Martin Hearson.

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