Multilateral Tax Treaties —— New Developments in International Tax Law

----- 多边税务协定

ISBN: 9789041107046 出版年：1997 页码：266 Lang, Michael Loukota, Helmut Kluwer Law International

The advantages and disadvantages of multilateral tax treaties have been debated for many years. Although some multilateral tax treaties have been concluded at regional level, the concept has not yet gained wide acceptance. It has become clear however, that diverging provisions in bilateral tax treaties lead to undesired consequences. Tax administrations expend considerable energy to combat tax structures devised by taxpayers and their advisers to attempt to use these differences to their advantage. This engages the resources of both enterprises and tax authorities without their efforts being useful from an economic point of view. This book is the result of 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's aim was to produce a draft multilateral tax treaty modelled on the OECD Model Income Tax Convention, whilst examining in detail difficulties that arise in connection with the multilateralisation of the OECD Model. The expert papers also present a detailed 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 Treaty provides incisive and thought-provoking reading for the international tax specialist and will undoubtedly generate further discussions on this important topic.Table of Contents:Introduction. 1. Most Favoured Nation Concept in Tax Treaties, Albert J R?dler. 2. Does the EC Treaty Force the EU Member States to Conclude a Multilateral Tax Treaty?, Franz Wassermeyer: 3. Bilateral Tax Treaties Multilateralised by the EC Treaty, Josef Schuch. 4. The Bilateral Tax Treaties Concluded between EU Member States, Gerald Toifl. 5. Multilateral Tax Treaty Versus Bilateral Treaty Network, Helmut Loukota. 6. The Elimination of Double Taxation Within the EU and between EU Member States and Non-Member States: Multilateral Treaty or Directive?, Christoph Urtz. 7. The Personal Scope of a Multilateral Tax Treaty, Michael Lang. 8. The Methods for the Elimination of Double Taxation in a Multilateral Tax Treaty, Josef Schuch. 9. Mutual Agreement and Arbitration Procedures in a Multilateral Tax Treaty, Mario Züger. 10. The Concept of a Multilateral Tax Treaty, Michael Lang. 11. Draft for a Multilateral Tax Treaty, Michael Lang, Josef Schuch, Christoph Urtz and Mario Züger: Index.