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A Global Analysis of Tax Treaty Disputes

A Global Analysis of Tax Treaty Disputes
2 Volume Hardback Set

Part of Cambridge Tax Law Series

Eduardo Baistrocchi, Yariv Brauner, Micah Burch, Arthur J. Cockfield, Ricardo Escobar, Mirenchu Muñoz, Georg Kofler, Jérôme Monsenego, Werner Haslehner, Emer Hunt, Carlo Garbarino, Toshio Miyatake, Oscar Echenique Quintana, Jorge E. Correa Cervera, Kees van Raad, Hans Muste, Frank Pötgens, Chang Hee Lee, Sunyoung Kim, Robert J. Danon, Billur Yalti, Timothy Lyons, Jason Whiston, Yongjun Peter Ni, Michael Littlewood, Isabel Calich, Joao Dacio Rolim, Irina Dmitrieva, Aseem Chawla, Ernie Lai King, Manuel M. Benites, Christiana H. J. I. Panayi, Margarita Liasi, Annet Wanyana Oguttu, Freddy Karyadi, Danny Darussalam, Ehtisham Ahmad, Fahad Al-Kharashi, Stephen Phua, Chai Sui Fun, Jinyan Li, Martin Hearson
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  • Publication planned for: July 2017
  • availability: Not yet published - available from July 2017
  • format: Multiple copy pack
  • isbn: 9781316507254

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  • This two-volume set offers an in-depth analysis of the leading tax treaty disputes in the G20 and beyond within the first century of international tax law. Including country-by-country and thematic analyses, the study is structured around a novel global taxonomy of tax treaty disputes and includes an unprecedented dataset with over 1500 leading tax treaty cases. By adopting a contextual approach the local expertise of the contributors allows for a thorough and transparent analysis. This set is an important reference tool for anyone implementing or studying international tax regulations and will facilitate the work of courts, tax administrations and practitioners around the world. It is designed to complement model conventions such as the OECD Model Tax Convention on Income and on Capital. Together with Resolving Transfer Pricing Disputes (2012), it is a comprehensive addition to current debate on the international tax law regime.

    • Provides law-in-context analysis of the international tax regime, with contributions from authors working in numerous jurisdictions
    • Features country-by-country and topic-by-topic analyses of leading tax treaty disputes
    • Includes a comprehensive dataset of over 1,500 leading tax treaty disputes as supplementary material
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    Product details

    • Publication planned for: July 2017
    • format: Multiple copy pack
    • isbn: 9781316507254
    • dimensions: 228 x 152 mm
    • contains: 67 b/w illus. 83 tables
    • availability: Not yet published - available from July 2017
  • Table of Contents

    Volume I: Acknowledgements
    List of contributors
    List of tables and charts
    List of cases
    The golden bridge - analytical table of cases by pattern of dispute
    Part I. The Context of Tax Treaty Disputes:
    1. Introduction Eduardo Baistrocchi
    Part II. OECD Countries:
    2. Tax treaty disputes in the United States Yariv Brauner
    3. Tax treaty disputes in Australia Micah Burch
    4. Tax treaty disputes in Canada Arthur J. Cockfield
    5. Tax treaty disputes in Chile Ricardo Escobar and Mirenchu Muñoz
    6. Tax disputes and the European Union Arbitration Convention Georg Kofler
    7. Tax treaty disputes in France Jérôme Monsenego
    8. Tax treaty disputes in Germany Werner Haslehner
    9. Tax treaty disputes in Ireland Emer Hunt
    10. Tax treaty disputes in Italy Carlo Garbarino
    11. Tax treaty disputes in Japan Toshio Miyatake
    12. Tax treaty disputes in Mexico Oscar Echenique Quintana and Jorge E. Correa Cervera
    13. Tax treaty disputes in The Netherlands Kees van Raad, Hans Muste and Frank Pötgens
    14. Tax treaty disputes in South Korea Chang Hee Lee and Sunyoung Kim
    15. Tax treaty disputes in Switzerland Robert J. Danon
    16. Tax treaty disputes in Turkey Billur Yalti
    17. Tax treaty disputes in the United Kingdom Timothy Lyons and Jason Whiston. Volume II:
    1. Introduction Eduardo Baistrocchi
    Part III. BRICS Countries:
    2. Tax treaty disputes in China Yongjun Peter Ni
    3. Tax treaty disputes in Hong Kong Michael Littlewood
    4. Tax treaty disputes in Brazil Isabel Calich and Joao Dacio Rolim
    5. Tax treaty disputes in Russia Irina Dmitrieva
    6. Tax treaty disputes in India Aseem Chawla
    7. Tax treaty disputes in South Africa Ernie Lai King
    Part IV. Countries beyond the OECD and BRICS:
    8. Tax treaty disputes in Argentina Manuel M. Benites
    9. Tax treaty disputes in Cyprus Christiana H. J. I. Panayi and Margarita Liasi
    10. Tax treaty disputes in Uganda Annet Wanyana Oguttu
    11. Tax treaty disputes in Indonesia Freddy Karyadi and Danny Darussalam
    12. Tax treaty disputes in Saudi Arabia Ehtisham Ahmad and Fahad Al-Kharashi
    13. Tax treaty disputes in Singapore Stephen Phua and Chai Sui Fun
    Part V. Conclusion:
    14. Patterns of tax treaty disputes: a global taxonomy Eduardo Baistrocchi
    15. Resolving tax treaty disputes: the global evolutionary path Eduardo Baistrocchi
    16. Triple non-taxation and BEPS: global implications Jinyan Li
    17. Tax treaty disputes: a global quantitative analysis Eduardo Baistrocchi and Martin Hearson.

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    A Global Analysis of Tax Treaty Disputes

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  • Editor

    Eduardo Baistrocchi, London School of Economics and Political Science
    Eduardo Baistrocchi is an Associate Professor of Law at the London School of Economics and Political Science (LSE). Before joining the LSE, he was Associate Professor of Law at Universidad Torcuato Di Tella, Buenos Aires. He studied law at the Universidad de Buenos Aires before obtaining an LLM at Harvard Law School, Massachusetts, and later an LLM on Tax Law at LSE. He has been a Fulbright Scholar and a Chevening Scholar. He has also been a Distinguished Visiting Professor at Northwestern University, Illinois and the University of Toronto. His research and publications are focused on international taxation, with a particular emphasis on tax treaty disputes in the G20. He applies interdisciplinary approaches, such as game theory, to investigate the operation of the international tax regime. He is the author of Resolving Transfer Pricing Disputes: A Global Analysis (with Ian Roxan, Cambridge, 2012) and his work has been published in leading journals such as the British Tax Review, the Modern Law Review and the Oxford Journal of Legal Studies.

    Contributors

    Eduardo Baistrocchi, Yariv Brauner, Micah Burch, Arthur J. Cockfield, Ricardo Escobar, Mirenchu Muñoz, Georg Kofler, Jérôme Monsenego, Werner Haslehner, Emer Hunt, Carlo Garbarino, Toshio Miyatake, Oscar Echenique Quintana, Jorge E. Correa Cervera, Kees van Raad, Hans Muste, Frank Pötgens, Chang Hee Lee, Sunyoung Kim, Robert J. Danon, Billur Yalti, Timothy Lyons, Jason Whiston, Yongjun Peter Ni, Michael Littlewood, Isabel Calich, Joao Dacio Rolim, Irina Dmitrieva, Aseem Chawla, Ernie Lai King, Manuel M. Benites, Christiana H. J. I. Panayi, Margarita Liasi, Annet Wanyana Oguttu, Freddy Karyadi, Danny Darussalam, Ehtisham Ahmad, Fahad Al-Kharashi, Stephen Phua, Chai Sui Fun, Jinyan Li, Martin Hearson

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