Practical Issues in the Application of Double Tax Conventions: Problemes Pratiques D'Application Des Conventions Contre La Double Imposition

By Ifa

Double tax conventions (DTCs) are growing in both number & complexity. As a result, the practical aspects of applying DTCs have increased in importance for tax authorities & taxpayers, & measures to ensure better operation of DTCs at a national level have a particular urgency. Results have included new rules for handling double tax claims, state transfers from exemption-based approaches to credit-based approaches to international tax issues, & the need for clarification of internal provisions & procedures in states transferring to a self-assessed tax. Despite the growing import of these issues, however, the application of tax conventions has received little attention in literature & debate. This book is unique in both its coverage & scientific approach. Rather than seeking to bolster pre-determined positions, the authors are genuinely looking for issues of import. The work surveys the issues reported from member states, seeking best practices that range from self-authorised claims or ready advance rulings to complex clearance procedures. It also notes problems, including substantial uncertainties for topics such as residence claims & withholding taxes. Focusing on the operation & use of double tax conventions from the taxpayers'viewpoint, this Cahier evaluates the extent to which DTC application processes affect the realisation of the objectives of the conventions. The topicality of the issue & the Cahier's unique approach make this an important work for tax practitioners, policymakers, & others interested in or affected by the way taxes are paid.

• Format: Hardcover
• Language: English
• ISBN: 904111002X
• ISBN13: 9789041110022
• Release Date: June 1998
• Publisher: Kluwer Law International
• Length: 768 Pages