ax agreement between countries. What is the position in your country? Is there a policy of active negotiation of treaties? Are there many tax treaties in force?
Why do we need a system of double tax treaties? What could be the results of not having treaties (think of some examples)?
How do treaties come into existence? Who and how can they be enforced? What is the foundation in law for a tax treaty?
What is the Vienna Convention on the Law of Treaties? What does it contain? Why is it important in tax law?
What are the rights and obligations under a tax treaty? What is treaty override? What are its consequences?
What are the principles of international taxation relevant to the application of tax treaties? At the public international level, does a treaty override domestic law (a) always (b) never (c) occasionally?
Can a tax treaty impose tax (a) never (b) always (c) sometimes? Can a taxpayer claim the benefits of more than one tax treaty with the same source state (a) no (b) yes (c) only if the source State agrees?
What is OECD? Why is it relevant in international taxation? Briefly summarise the historical development of the OECD Model treaty?
Describe the structure of a Model treaty? What are the main benefits of the model tax treaty?
What is the legal significance of the OECD Model treaty and commentary under domestic or international law? Does it differ from the Model treaty and commentary?
Why do the UN and US Models differ from the OECD Model treaty? Please bullet point five specific differences between the OECD Model convention and the UN Model convention.
How might dual residence occur for (a) an individual and (b) a company, and how do you think it might be treated form your reading and under the OECD Model? Can you define effective management in your own words?
What are the various sources for interpretation of tax treaties? When interpreting a tax treaty, should you apply (a) the OECD Model treaty (b) the commentary, (c) the negotiated bilateral treaty, (d) domestic tax law or (e) legal decisions? In case of conflict in the domestic tax law of the two states, which state law should be applied?
Define the term ‘permanent establishment’ used in tax treaties. Why is it important in international taxation? What factors constitute a permanent establishment? What factors are excluded from a permanent establishment? How do the rules differ between OECD and UN Models?
If a permanent establishment exists, how are the taxing rights allocated on business profits under Article 7?
How does a tax treaty attribute business income to ‘permanent establishments’? What is a separate entity approach? How are expenses allocated? What is the treatment of purchasing activities? How can double taxation arise?
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