Tag Archives | International Tax Law

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 countries since they believe that [...]

By |2016-06-22T16:01:11+00:00June 22, 2016|International Taxation|Comments Off on OECD Initiative on Harmful Tax Competition

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 the UN Group of Experts [...]

By |2016-06-22T16:01:10+00:00June 22, 2016|International Taxation|Comments Off on Multilateral Tax Agreement

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 to interpret tax treaties. Most [...]

By |2016-06-22T16:01:10+00:00June 22, 2016|International Taxation|Comments Off on Legal Decisions on Treaty Interpretations
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