Introduction to the Law of Double Tax Conventions

Cross-border activities or transactions may trigger tax liability in two or more jurisdictions. In order to mitigate the financial burden resulting from these situations, states have entered into numerous double taxation conventions, which provide for rules that allocate the taxing rights between the contracting states. This book provides an introduction to the law of double taxation conventions. Although principally aimed at students, the book will be of value to tax experts, wishing to gain a better understanding of double taxation conventions, as well as international law experts, seeking to increase their knowledge of tax law. Through examples from different countries and their jurisdictions, the book gives a truly global overview. The problem of double taxation, the state practice in the conclusion of DTCs and their effects, the interpretation of double taxation conventions and treaty abuse are also discussed in detail. Finally, the book analyses all provisions of the OECD and UN Model Tax Conventions on Income and on Capital and the OECD Model Convention on Estate, Inheritance and Gift Tax. About the author Since 1994 Michael Lang has been a Professor of tax law, specializing in international tax law. Univ.-Prof. Dr. Dr. h.c. Lang is currently the Head of the Institute for Austrian and International Tax Law at the WU (Vienna University of Economics and Business).