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Citizenship and Residence Sales
The first interdisciplinary empirically-grounded pluri-jurisdictional assessment of the origins, operation and main causes of the growing global investment migration trend.
The Glorification of Plunder
This book is about two things: tax and power. The processes through which tax law is formulated, involve more than the formal legislative and judicial processes which result in statute and case law. Tax law is an expression of tax policy, which is subjective and a heterogeneous product of states, cultures and politics. Regarding taxation as a branch of either black letter law or orthodox economics ignore, or even deny, this subjectivity. This book explores the complex dynamics of the debates which inform tax policy, the interaction between tax and power and how power relations between various groups in society and between individuals and the state are manifested through tax system. This help...
International Commercial Agreements
Precise planning, drafting and vigorous negotiation lie at the heart of every international commercial agreement. But as the international business community moves toward the third decade of the twenty-first century, a large amount of the detail of these agreements has migrated to the Internet and has become part of electronic commerce. This incomparable one-volume work, now in its seventh edition, begins by discussing and analyzing all the basic components of international contracts regardless of whether the contracting parties are interacting face-to-face or dealing electronically at some distance from each other. The work stands alone among contract drafting guides and has proven its endu...
Preventing Treaty Abuse
Analysis of notion, roots und measures of treaty abuse The OECD initiative on Base Erosion and Profit Shifting has put the issue of treaty abuse and the means to counter it on top of the global political agenda. Preventing treaty abuse is therefore currently one of the most debated topics in international tax law. Diverging national legal traditions in combatting abuse both under domestic and tax treaty law have led to a globally diversified legal framework in this respect and make the OECD’s agenda to harmonize these attempts even more challenging. The aim of this book is to analyze the notion of treaty abuse, its historical roots and the measures to counter it. The book’s topics cover ...
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The Taxation of Fees for Technical Services on the Basis of Article 12A UN Model Convention
Although rules on the allocation of taxing rights for fees for technical services have been provided for in bilateral tax treaties by African, Asian, and South American countries for decades, it was only in the 2017 update that the UN Model Tax Treaty included Article 12A on the matter, thus suggesting its inclusion in the tax treaty network of its Member States. Consequently, from a cross-border perspective, the interpretation of Article 12A is of great importance for both taxpayers and tax authorities. This book presents the first comprehensive analysis of the scope of technical services in comparison to ordinary (non-technical) services and the differentiation between Article 12A and othe...
Special Features of the UN Model Convention
Detailed research on the UN Model Convention’s unique features The UN Model Convention has a significant influence on international tax treaty practice and is especially used by emerging and developing countries as a starting point for treaty negotiations. Driven by the aim to achieve consistency in the international tax treaty practice, the structure and content is, to a large extent, similar in the UN Model and the OECD Model. However, whereas the OECD has historically focused its efforts on issues mainly relevant for developed countries, the UN Tax Committee has continuously attempted to specifically take into account tax treaty policies for developing countries when drafting and amendi...
Principles of International Taxation
This highly accessible text provides a clear introduction to international taxation as well as more in-depth material on many essential areas of the subject. Whilst using some examples from the UK tax system, it presents its material in a global context, explaining the variety of approaches used around the world to deal with the key issues that arise in international tax.
Taxation, Citizenship and Democracy in the 21st Century
Proposing innovative ideas on the links between taxation, citizenship and democracy, this multidisciplinary book contributes to ongoing research and scholarship by emphasizing the importance of taxes to the functioning of democracy.
Studies in the History of Tax Law, Volume 5
These are the papers from the 2010 Tax law History Conference. The papers reflect an even wider range of topics, including problems in defining and taxing Companies from 1799 to 1965, the Window tax from a Public Health perspective, the development of the tax profession, Montesquieu and ERA Seligman, taxing charities in Australia, Charitable Purposes Exemption from Income Tax: Pitt to Pemsel 1798 – 1891 and Australian perspectives on avoiding evasion. Turning to international tax there are essays on the history of the international taxation of income from enterprise services, the Negotiation and Drafting of the 1967 United Kingdom Australia Taxation Treaty and on art 7 (3) of the OECD Model Treaty.
