Michael Lang

Pasquale Pistone

Josef Schuch

Claus Staringer

Alexander Rust, LL.M. (NYU)

The expected post-BEPS project changes to the Model Convention As a result of the Actions under the BEPS Action Plan, the OECD plans to update its Model Convention in the near future. The proposed changes particularly concern the introduction of savings and limitation on benefits clauses, reconsideration of the treaty entitlement for fiscally transparent entities and articulation of various proposals with regard the current concept of permanent establishment and limitations on the abuse thereof. This book includes 12 chapters that analyse the expected post-BEPS project changes to the Model Convention and the possibility of updating treaties on the basis of the multilateral instrument, rather than bilateral negotiations. The book incorporates the perspectives of leading scholars and practitioners dealing with international tax matters. Essential insights are provided for academics, practitioners, tax officials and judges who deal with or are interested in the field of international taxation.

Schriftenreihe IStR Band 96

Base Erosion and Profit Shifting (BEPS)

Jeffrey Owens

Alfred Storck

Eric Kemmeren

Peter Essers

Daniel S. Smit

A Global Overview of International Tax Disputes on DTC This book is a unique publication that gives a global overview of international tax disputes on double tax conventions and thereby fills a gap in the area of tax treaty case law. It covers the forty-three most important tax treaty cases which were decided in 2014 around the world. The systematic structure of each case allows the easy and efficient study and comparison of the various applications and interpretation of tax treaties in different regimes. Never before have tax treaty court decisions around the world been presented in such a comprehensive and structured way. With the continuously increasing importance of tax treaties, the proposed book is a valuable resource and a must for all practitioners, multinational businesses, policy makers, tax administrators, judges and academics who are active in tax treaty case law.

Schriftenreihe IStR Band 97

Tax Treaty Case Law around the Globe 2015

Alexander Rust, LL.M. (NYU)

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