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A Global Analysis of Tax Treaty Disputes

A Global Analysis of Tax Treaty Disputes
2 Volume Hardback Set

$375.00 (R)

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 HJI Panayi, Margarita Liasi, Annet Wanyana Oguttu, Freddy Karyadi, Darussalam, Ehtisham Ahmad, Fahad Al-Kharashi, Stephen Phua, Chai Sui Fun, Jinyan Li, Martin Hearson
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  • Date Published: September 2017
  • availability: In stock
  • format: Multiple copy pack
  • isbn: 9781316507254

$ 375.00 (R)
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About the Authors
  • 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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    Reviews & endorsements

    'This will be a crucial addition to the practitioner’s library shelves. Both in international tax planning, and in controversy work, being able to bring to bear the decisions of foreign courts on tax treaty issues is often a powerful technique. Even from an early review of the proofs, I found relevant materials for current ‘live’ work in the areas of permanent establishments, beneficial ownership and treaty override. The global case law taxonomy and 'golden bridge' indexing assist with navigation and will provide an interesting evolution of treaty dispute patterns in future editions.' Murray Clayson, Freshfields Bruckhaus Deringer LLP and President of the International Fiscal Association, The Netherlands

    'Eduardo Baistrocchi’s outstanding new book on tax treaty disputes is the result of an intense five-year global collaborative project among international tax scholars, practitioners and administrators. The book provides an unprecedented set of information and offers the first global qualitative and quantitative analysis on one of the most important debates over international tax scholarship across the last decades, that is, whether an international tax regime exists and is binding upon states as a matter of customary international law.' Reuven Avi Yonah, Tax Notes International

    'This two-volume book deserves to be mentioned because of its exceptionally rich content and its original approach. … At a time of harmonization of international tax law at a global level, this treatise is particularly welcome.' Daniel Gutmann, Translated from Revue de Droit Fiscal

    'The volume charts a new course and should be explored by professionals interested in international taxation and, in particular, by those working on dispute resolution pertaining to tax treaties.' Parthasarathi Stone, Business Standard

    'This is an important addition to the international tax disputes literature containing interesting statistics, a useful categorisation of cases from different countries on a particular topic, and a wide range of country chapters.' John Avery Jones, British Tax Review

    ‘Based on the country-by-country analysis of the leading tax treaty disputes in 27 jurisdictions, this book drew four significant conclusions on the cutting edge issues of contemporary international tax law, ranging from global taxonomy of the patterns of tax treaty disputes, global evolutionary path of tax treaty dispute resolution, implications of triple non-taxation and BEPS, and to global quantitative analysis of tax treaty disputes.’ Haiyan Xu, Beijing Law Review

    'The main interest of the treatise lies in its comprehensiveness as well as in its critical approach to the subject. It is a very ambitious work containing the largest compilation to date in one single book of cases dealing with controversies related to double taxation treaties. Roughly 1,600 cases are cited related to the application of treaties listed both country-by-country and thematically. The cases are listed in the treatise’s first volume, which offers a classification based on various criteria, i.e., the country where the controversy takes place and, also, in the so-called 'Golden Bridge', an analytical listing of cases sorted out according to the precepts of the OECD Model Convention. This listing, along with the chart on page 1443, offers a unique picture of the type of controversies that have been resolved within the 1923 to 2015 timeframe covered by the treatise.' Violeta Ruiz Almendral, Crónica Tributaria

    'Baistrocchi’s collection is a must-have for readers interested in tax treaties. It might aptly be referred to as 'the definitive encyclopedia on tax treaty case law'. Work by 42 authors spans 27 countries and provides an analysis of over 580 tax treaty cases. … This review does not do justice to the rich resource that this double volume provides for tax practitioners, policy makers, and scholars with an interest in tax treaty disputes. It is a stand-out contribution in the area.' Kim Brooks, Revue fiscale canadienne

    ‘Both Eduardo Baistrocchi and his publisher Cambridge University Press are to be congratulated for having the courage, energy and discipline to produce this excellent publication. A book, even in two volumes, with the title A Global Analysis of Tax Treaty Disputes might ordinarily seem to be an over-ambitious project but this publication is a triumph. There are both scope and scale in this book which makes it unique in tax academic literature. The publication will also be immensely valuable in taxation practice, administration and jurisprudence for reasons discussed below. In short, the book is a remarkable reflection of legal analysis and likely to be of huge assistance in international tax disputes, but more generally in tax legal scholarship.’ Craig Elliffe, Australian Tax Review

    ‘A Global Analysis of Tax Treaties Disputes helps in identifying both promises and risks, and is an invaluable resource for policymakers in designing their next move as well as for the future assessment of new policies.’ Tsilly Dagan, Modern Law Review

    ‘… the book contributes for a better understanding of the metalanguage that has been developed in the International Tax Law. It also arrives at a good time because it marks the end of a period (the pre-BEPS period), offering a safe base that serves as a starting point for the analysis of the international scenario that will arise from now on.’ Luís Eduardo Schoueri, Translated from Revista Direito Tributário Internacional Atual

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    Product details

    • Date Published: September 2017
    • format: Multiple copy pack
    • isbn: 9781316507254
    • dimensions: 235 x 81 x 159 mm
    • weight: 2.87kg
    • contains: 67 b/w illus. 83 tables
    • availability: In stock
  • Table of Contents

    Volume 1. OECD Countries: 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 2. BRICS Countries and Beyond:
    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 HJI Panayi and Margarita Liasi
    10. Tax treaty disputes in Uganda Annet Wanyana Oguttu
    11. Tax treaty disputes in Indonesia Freddy Karyadi and 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 Associate Professor of Law at the London School of Economics and Political Science (LSE). He studied law at the Universidad de Buenos Aires before obtaining an L.L.M. at Harvard Law School and later an L.L.M. on Tax Law at LSE. He has been a Fulbright Scholar and a Chevening Scholar. He has also been a Distinguished Visiting Professor in Brazil (FGV Direito Sao Paulo), Canada (University of Toronto) and the United States (Northwestern University). 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 and public choice, to investigate how the international tax regime operates. He has published in leading journals and publishing houses such as the British Tax Review, the Global Tax Treaty Commentaries, the Modern Law Review, the Oxford Journal of Legal Studies (OJLS) and Cambridge University Press.

    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 HJI Panayi, Margarita Liasi, Annet Wanyana Oguttu, Freddy Karyadi, Darussalam, Ehtisham Ahmad, Fahad Al-Kharashi, Stephen Phua, Chai Sui Fun, Jinyan Li, Martin Hearson

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