Tag Archives | International Tax Law

Vienna Convention on the Law of Treaties (VCLT)

In this article we will discuss about the Vienna Convention on the Law of Treaties (VCLT). (i) Background: The rules under the Vienna Convention on the Law of Treaties (VCLT) apply to all international treaties, including tax treaties. The Vienna Convention on the Law of Treaties (VCLT) was adopted on May 22, 1969 and entered […]

Model Tax Conventions: Background and Benefits

In this article we will discuss about the model tax conventions:- 1. Historical Background of Model Tax Conventions 2. How do Model Tax Treaties Work 3. Relief against Juridical Double Taxation 4. Benefits of the Model Tax Treaties – Some Examples 5. OECD and UN Model Conventions – Comments. Contents: Historical Background of Model Tax […]

Treaty of European Union

In this article we will discuss about the treaty of European union. Introduction to Treaty of European Union: Several European countries established a common market under the Treaty of Rome (effective from 1958). This European Economic Community was eventually superseded by the Treaty of European Union (also called the Treaty of Maastricht or EC Treaty), […]

OECD Initiative on Harmful Tax Competition

In this article we will discuss about:- 1. Background of OECD Initiative 2. Historical Development of OECD Initiative 3. Comments. Background of OECD Initiative: Harmful competition arises due to mismatches in the existing tax systems of countries that can be exploited by taxpayers. Such economic behaviour may be considered as unacceptable tax avoidance by certain […]

Multilateral Tax Agreement

This article provides a note on multilateral tax agreement. Introduction to Multilateral Tax Agreement: There have been several efforts to agree on a multilateral tax treaty. In 1958, the OEEC Fiscal Committee attempted to draft a multilateral convention but was unsuccessful due to the difficulties of definition and application. Similar conclusions were also reached by […]

Legal Decisions on Treaty Interpretations

In this article we will discuss about the legal decisions on treaty interpretations:- 1. Legal Interpretations 2. Reference to the VCLT 3. Reference to the OECD MC and Commentaries 4. Other Judicial Decisions 5. Country Examples.  Legal Interpretations: Although double tax treaties are international agreements under public international law, there is no international judicial authority […]

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