The History of Double Taxation Conventions in the Pre-BEPS Era

The History of Double Taxation Conventions in the Pre-BEPS Era
This book analyses the evolution of tax treaties practices from the early days of the history of international taxation until the beginning of the BEPS era.

Why this book?

The design of international tax law cannot be described without recourse to its extensive history. By looking at the evolution of tax treaties, valuable insight is gained as regards the causes behind the most recent shift towards renewed international tax coordination in the framework of the BEPS Project. This book analyses how tax treaties have evolved, from the early days of the history of international taxation until the beginning of the BEPS era, by collecting the outcome of joint research on the development of international tax law. It consists of a wide range of papers bridging the existing gap between the history of international law, economic history and the history of international cooperation.

In this context, it also spells out the importance of the role of early institutions such as the International Chamber of Commerce and the League of Nations, as well as the International Fiscal Association and the OEEC/OECD, and helps to highlight their fundamental influence. The book is the result of the conference “History of Double Taxation Conventions”, which took place from 3-5 July 2008 in Rust/Neusiedler See. It consists of 30 contributions exploring the development of the tax treaty practices of 30 countries and, additionally, three cross-sectional contributions.

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This book is part of the WU Institute for Austrian and International Tax Law - Tax Law and Policy Series

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Editor(s)

Michael Lang is professor at WU Vienna University of Economics and Business, Institute for Austrian and International Tax Law. Ekkehart Reimer is professor at Heidelberg University, Institute for Public Finance and Tax Law.

Contributor(s)

Raymond Adema, Tiiu Albin, José Almeida Fernandes, Hrvoje Arbutina, John F. Avery Jones, Tomas Balco, Christoph Bräunig, Yariv Brauner, Kim Brooks, Irene Burgers, Brian Cleave, Dev R. Erriah, Friederike Gorgiev-Oberascher, María Amparo Grau Ruiz, Charles H. Gustafson, Lidija Hauptman, Judita Holczerová, Chaowu Jin, Horace King, Borbála Kolozs, Franz Koppensteiner, Nataša Žunić Kovačević, Jana Kubicová, Georgios Matsos, Yuri Matsubara, Shay N. Menuchin, Irma Johanna Mosquera Valderrama, Danuse Nerudova, Bettina zur Nieden, Helen Pahapill, Andrea Parolini, Ciprian Adrian Păun, Susanne Raas, Daniel P. Rentzsch, Isabelle Richelle, Luís Eduardo Schoueri, Nico Schutte, Andrew M.C. Smith, Viktar Strachuk, Sabina Taškar Beloglavec, C. John Taylor, Karolina Tetłak, Andreas Their, Edoardo Traversa, Richard Vann, Danil V. Vinnitskiy.

The History of Double Taxation Conventions in the Pre-BEPS Era
Chapter 1: Some Observations on the Transition from Tax Statehood to International Taxation
Chapter 2: Writing Tax Treaty History
Chapter 3: The Definition of Company Residence in Early UK Tax Treaties and Its Influence on the OECD Model
Chapter 4: The History of Austria’s Double Tax Conventions
Chapter 5: The History of Germany’s Double Tax Conventions
Chapter 6: The History of Swiss Double Tax Conventions
Chapter 7: The History of Hungarian Double Tax Conventions
Chapter 8: The History of Dutch Double Tax Conventions
Chapter 9: The History of Belgian Double Tax Conventions
Chapter 10: The History of Italy’s Double Tax Conventions
Chapter 11: The History of Poland’s Double Tax Conventions
Chapter 12: The History of Czech Double Tax Conventions
Chapter 13: The History of Slovakia’s Double Tax Conventions
Chapter 14: The History of Spain’s Double Tax Conventions
Chapter 15: The History of Portugal’s Double Tax Conventions
Chapter 16: The History of Brazilian Tax Treaties
Chapter 17: The History of Colombian Double Tax Conventions
Chapter 18: The History of UK Double Tax Conventions
Chapter 19: The History of US Double Tax Conventions
Chapter 20: The History of Canada’s Double Tax Conventions
Chapter 21: The History of Australia’s Double Tax Conventions
Chapter 22: The History of New Zealand’s Double Tax Conventions
Chapter 23: The History of Mauritius’ Double Tax Conventions
Chapter 24: The History of Israel’s Double Tax Conventions
Chapter 25: The History of Slovenia’s Double Tax Conventions
Chapter 26: The History of Croatia’s Double Tax Conventions
Chapter 27: The History of Romania’s Double Tax Conventions
Chapter 28: The History of Greek Double Tax Conventions
Chapter 29: The History of Russia’s Double Tax Conventions
Chapter 30: The History of Belarusian Double Tax Conventions
Chapter 31: The History of Estonia’s Double Tax Conventions
Chapter 32: The History of Japan’s Double Tax Conventions
Chapter 33: The History of China’s Double Tax Conventions: From Inequity to Equity