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Klaus Vogel on Double Taxation Conventions, Fourth Edition by VOGEL

Klaus Vogel on Double Taxation Conventions, Fourth Edition

Edited by Ekkehart Reimer, Alexander Rust,
By Johannes Becker, Michael Blank, Axel Cordewener, Luc De Broe, Ana Paula Dourado, Daniela Endres, Werner Haslehner, Roland Ismer, Eric CCM Kemmeren, Georg Kofler, Katharina Riemer, Matthias Valta, Kamilla Zembala


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Klaus Vogel on Double Taxation Conventions is regarded as the international gold standard on the law of tax treaties. This new Fourth Edition has been completely revised and updated to give you a full and current account of double tax conventions (DTCs).

DTCs form the backbone of international taxation, but they raise many interpretational questions. This market leading work will provide you with the answers.

Based on the OECD MC and Commentary published in July 2014, the book also includes relevant case law and scholarly literature from 2014.

This last edition has been cited by courts world-wide, including

  • an Australian Administrative Appeals Tribunal
  • the Hoge Raad of the Netherlands
  • courts of India, ranging from Income Tax Appellate Tribunals to the Supreme Court
  • the Tax Chamber of First-Tier Tribunals in the United Kingdom

Likewise, previous editions of the Vogel have been cited by courts in Canada, Germany, South Africa, and the Netherlands.

What’s new in this edition?

There have been many important developments in this area since the last edition in 1997. The authors discuss these developments and the effect they will have upon practitioners working in this area. They also provide a wealth of new and revised case law, along with the DTCs of emerging countries.

You’ll find:

  • Reports about major features in the DTC practice of many leading jurisdictions, such as:
  1. the DTC practice of Austria, Canada, France, Germany, India, the Netherlands, Switzerland, the UK and the US
  2. Sections on divergent country practice covering their national models and networks of bilateral DTCs
  • Thorough analysis of the OECD and UN model, as well as the implementation of these models in practice
  • Coverage of a full range of the latest tax treaties around the world, including important treaties between OECD and BRICS countries

This new Fourth Edition of Klaus Vogel on Double Taxation Conventions continues to reflect the unchallenged role of the OECD. The OECD MC, accompanied by the official Commentary, guidelines, reports and other recommendations, has sustained its position as the most important legal instrument in the area of DTCs.

On occasion, the UN MC and Commentary diverge from the OECD texts. When this happens, the authors deal with the specifics of the UN MC in separate annotations and analyses, explaining and making sure you understand the differences.

How this will help you:

  • All the information you need to confidently advise on issues such as the taxation of income, taxation of capital and the elimination of double taxation
  • Know that your advice to clients is based on the most up-to-date and respected information available, from an outstanding team of editors and authors

The editors, Professors Ekkehart Reimer and Alexander Rust, have worked with the late Professor Vogel as well as a new international team of top experts to completely update and enhance the content. The writing team comprises:


Prof. Dr Ekkehart Reimer, Heidelberg University and Prof. Dr Alexander Rust, WU Vienna.


Johannes BeckerHeidelberg UniversityMichael BlankUniversity of Erlangen-NurembergProf. Dr Luc De Broe, Catholic University of Leuven; Laga; Prof. Dr Axel Cordewener, Flick Gocke Schaumburg ; Prof. Dr Ana Paula DouradoUniversity of LisbonDaniela Endres, University of Erlangen-NurembergProf. Dr Werner HaslehnerUniversity of LuxembourgProf. Dr Roland IsmerUniversity of Erlangen-NurembergProf. Dr Eric C. C. M. Kemmeren , Tilburg UniversityProf. Dr Georg KoflerUniversity of Linz ; Katharina Riemer, Heidelberg University ; Prof. Dr Ekkehart Reimer, Heidelberg University;  Prof. Dr Alexander RustWU Vienna; Prof. Dr. Matthias Valta, Heidelberg University; Kamila Zembala, Heidelberg University

Resources Table of Contents
Pages 2128
Publish Date 02/26/2015
Publish Frequency As Needed
Product Line Kluwer Law International
ISBN 9789041122988
SKU 10057643-0001
Table of Contents

Chapter I. Scope of the Convention

  • Article 1. Persons Covered
  • Article 2. Taxes Covered

Chapter II. Definitions

  • Article 3. General Definitions
  • Article 4. Resident-Residence
  • Article 5. Permanent Establishment

Chapter III. Taxation of Income

  • Article 6. Income from Immovable Property
  • Article 7. Business Profits
  • Article 8. Shipping, Inland Waterways Transport and Air Transport
  • Article 9. Associated Enterprises
  • Preface to Articles 10-12
  • Article 10. Dividends
  • Article 11. Interest
  • Article 12. Royalties
  • Article 13. Capital Gains
  • Ex-Article 14. Independent Personal Services
  • Article 15. Income from Employment
  • Article. 16. Directors’ Fees
  • Article 17. Entertainers and Sportspersons
  • Article 18. Pensions
  • Article 19. Government Service
  • Article 20. Students
  • Article 21. Other Income

Chapter IV. Taxation of Capital

  • Article 22. Capital

Chapter V. Methods for Elimination of Double Taxation

  • Article 23 A. Exemption Method
  • Article 23 B. Credit Method

Chapter VI. Special Provisions

  • Article 24. Non-Discrimination
  • Article 25. Mutual Agreement Procedure
  • Article 26. Exchange of Information
  • Article 27. Assistance in the Collection of Taxes
  • Article 28. Members of Diplomatic Missions and Consular Posts
  • Article 29. Territorial Extensions

Chapter VII. Final Provisions

  • Article 30. Entry into Force
  • Article 31. Termination
  • Index








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