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Multilateral Tax Treaties
Multilateral Tax Treaties
By Michael Lang, Helmut Loukota, Albert J. Rädler, Josef Schuch, Gerald Toifl, Christoph Urtz, Franz Wassermeyer
Kluwer Law International
Differing provisions in bilateral tax treaties lead to undesired consequences. Tax administrations expend considerable energy combating tax structures devised by taxpayers and their advisers who attempt to use these differences to their advantage. This battle uselessly engages the resources of both enterprises and tax authorities. A model multilateral tax treaty could provide the solution to this problem. The advantages and disadvantages of multilateral tax treaties have been debated for many years. While some multilateral tax treaties have been concluded at regional levels, the concept has yet to gain wide acceptance. Multilateral Tax Treaties results from a research project conducted at the Department for Austrian and International Tax Law at the University of Economics and Business Administration in Vienna. The project sought to produce a draft multilateral tax treaty modeled on the OECD Model Income Tax Convention while examining in detail difficulties that arise in connection with the multilateralisation of the OECD Model. The expert papers also present a thorough analysis of the arguments for and against the conclusion of a multilateral tax treaty and of the various European law issues that arise in this context. Multilateral Tax Treaties provides incisive and thought-provoking reading for the international tax specialist and generates further discussion on this important topic.
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List of Contributors, Preface, List of Abbreviations Chapter 1 Most Favoured Nation Concept in Tax Treaties Albert J. Radler Chapter 2 Does the EC-Treaty Force the EU Member States to Conclude a Multilateral Tax Treaty? Franz Wassermeyer Chapter 3 Bilateral Tax Treaties Multilateralized by the EC Treaty Josef Schuch Chapter 4 The Bilateral Tax Treaties Concluded Between EU Member States Gerald Toijl Chapter 5 Multilateral Tax Treaty Versus Bilateral Treaty Network Helmut Loukota Chapter 6 The Elimination of Double Taxation Within the EU and Between EU-Member States and Non-Member-States- Multilateral Treaty or Directive? Christoph Urtz Chapter 7 The Personal Scope of a Multilateral Tax Treaty Michael Lang Chapter 8 The Methods for the Elimination of Double Taxation in a Multilateral Tax Treaty Josef Schuch Chapter 9 Mutual Agreement and Arbitration Procedures in a Multilateral Tax Treaty Mario Ziiger Chapter 10 The Concept of a Multilateral Tax Treaty Michael Lang Chapter 11 Draft for a Multilateral Tax Treaty Michael Lang/Josef Schuch/Christoph Urtz/Mario Ziiger, Index