Avoidance of Double Non-Taxation

Double non-taxation is generaly considered to be an undesirable effect resulting from the application of a tax treaty. Therefore, several approaches have recently been developed to avoid this undesirable result. The OECD committee and Fiscal Affairs dealt with that issue when the OECD Model Convention and the Commentaries were modified, tax treaty negotiators insert certain specific provisions to avoid non-taxation by having that purpose in mind when applying a certain tax treaty provision. 19 National Reports from nearly all EU countries as well as the Czech Republic. Latvia, Poland, Russia, and Slovakia dealt with this topic and have been compiled and published in this volume.