A Global Analysis of Tax Treaty Disputes (ed.) (London: Cambridge University Press, 2017)
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.
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Reviews:
Matthieu Possoz, Revue de droit international et de droit comparé, 2019, n° 2, pp 329-330 (Belgium)
Professor Frans Vanistendael, INTERTAX, 2019, Volume 47, Issue 4, pp 416-417
Daniel Gutmann, Revue de Droit Fiscal, N° 46, 16 November 2017, p. 12 (France)
Reuven S. Avi-Yonah, “Are Taxes Converging?”, Tax Notes International, 27 November, 2017, pp. 889-891 (United States of America)
Parthasarathi Shome, Global Trends in Tax Disputes, Business Standard, 30 November 2017 (India)Standard (India)
John Avery Jones, British Tax Review, N° 5, December 2017, pp. 669-671 (United Kingdom)
Haiyan Xu, Beijing Law Review, N° 9, May 2018, pp. 132-136 (People´s Republic of China)
Violeta Ruiz Almendral, Crónica Tributaria, N° 166, 2018, Instituto de Estudios Fiscales, pp. 239-242 (Spain)
Kim Brooks, Canadian Tax Journal, 2018, 66:2, pp. 507-508 (Canada)
Luís Eduardo Schoueri, Revista Direito Tributário Internacional Atual nº 03 p.159-162 – 2018 (Federative Republic of Brazil)
Marcus Livio Gomes, Revista de Direito Internacional Econômico e Tributârio, Brasília, V. 12, nº2, p. 1-5 Jul-Dez, 2017 (Federative Republic of Brazil)
Craig Elliffe, Australian Tax Review, 2018, Volume 47, N° 2 pp. 160-161 (Australia)
Tsilly Dagan, Modern Law Review, 2018, Volume 81, N°4, pp 730-733 (United Kingdom)
Resolving Transfer Pricing Disputes: A Global Analysis (ed. with Ian Roxan) (London: Cambridge University Press. 2012)
Via a global analysis of more than 180 transfer pricing cases from 20 representative jurisdictions, Resolving Transfer Pricing Disputes explains how the law on transfer pricing operates in practice and examines how disputes between taxpayers and tax administrations are dealt with around the world. It has been designed to be an essential complement to the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, which focus on transfer pricing issues but do not refer to specific transfer pricing disputes. All of the transfer pricing cases discussed in the book are linked to the relevant paragraphs of the OECD Guidelines by means of a 'Golden Bridge', namely a table listing the cases according to the paragraphs of the Guidelines to which they refer. It therefore provides examples of the application of the Arm's Length Principle in many settings on all continents.
[this review was first published by Thomson Reuters (Professional) UK Limited in British Tax Review (2013) Vol.58 British Tax Review, Issue 5 and is reproduced by agreement with the Publishers]