Multilateral Tax Treaties: New Developments in International Tax Law: 18 (International Taxation, 18) - Tapa dura

Differing provisions in bilateral tax treaties lead to undesired consequences. Tax administrations expend considerable energy combating tax structures devised by taxpayers and their advisers who attempt to use these differences to their advantage. This battle uselessly engages the resources of both enterprises and tax authorities. A model multilateral tax treaty could provide the solution to this problem. The advantages and disadvantages of multilateral tax treaties have been debated for many years. While some multilateral tax treaties have been concluded at regional levels, the concept has yet to gain wide acceptance. Multilateral Tax Treaties results from a research project conducted at the Department for Austrian and International Tax Law at the University of Economics and Business Administration in Vienna. The project sought to produce a draft multilateral tax treaty modeled on the OECD Model Income Tax Convention while examining in detail difficulties that arise in connection with the multilateralisation of the OECD Model. The expert papers also present a thorough analysis of the arguments for and against the conclusion of a multilateral tax treaty and of the various European law issues that arise in this context. Multilateral Tax Treaties provides incisive and thought-provoking reading for the international tax specialist and generates further discussion on this important topic.

The advantages and disadvantages of multilateral tax treaties have been debated for many years. Although some multilateral tax treaties have been concluded at regional level, the concept has not yet gained wide acceptance. Recently it has become clear, however, that diverging provisions in bilateral tax treaties lead to undesired consequences. Tax administrations expend considerable energy combatting tax structures devised by taxpayers and their advisers, in an attempt to use these differences to their advantage. This engages the resources of both enterprises and tax authorities without their efforts being useful from an economic point of view. This book is the result of a research project conducted at the Department for Austrian and International Tax Law at the University of Economics and Business Administration in Vienna. The project's aim was to produce a draft multilateral tax treaty modelled on the OECD Model Income Tax Convention, whilst examining in detail difficulties that arise in connection with the multilateralization of the OECD Model.