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Double Taxation and the League of Nations

$116.00 USD

Part of Cambridge Tax Law Series

  • Date Published: April 2018
  • availability: This ISBN is for an eBook version which is distributed on our behalf by a third party.
  • format: Adobe eBook Reader
  • isbn: 9781108383745

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  • Modern-day tax treaties have their foundations in one of the three Model Tax Treaties developed by the League of Nations in 1928. Using previously unexplored archival material, Sunita Jogarajan provides the first in-depth examination of the development of the League's Models. This new research provides insights into questions such as the importance of double taxation versus tax evasion; the preference for source-taxation versus residence-taxation; the influence of theory and practice on the League's work; the development of bilateral rather than multilateral treaties; the influence of developing countries on the League's work; the role of Commentary in interpreting model tax treaties; and the influential factors and key individuals involved. A better understanding of the development of the original models will inform and help guide interpretation and reform of modern-day tax treaties. Additionally, this book will be of interest to scholars of international relations and the development of law at international organisations.

    • Fills a gap in the literature on double taxation
    • The first study of the archival evidence on the establishment of the first model tax treaties dealing with double taxation
    • Highlights relevant aspects of later tax treaty developments and the current OECD Model
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    Product details

    • Date Published: April 2018
    • format: Adobe eBook Reader
    • isbn: 9781108383745
    • contains: 5 tables
    • availability: This ISBN is for an eBook version which is distributed on our behalf by a third party.
  • Table of Contents

    Preface
    List of abbreviations
    1. Introduction
    2. Background
    3. Personality, politics and principles: the drafting of the 1925 Resolutions on Double Taxation
    4. The ICC and the development of the 1928 Models
    5. Turning resolutions into treaties – the drafting of the first Model Convention on Double Taxation
    6. The 'great powers' and the development of the 1928 Models
    7. One beget three – the drafting of the 1928 Model Tax Treaties on Double Income Taxation
    8. Lessons from history – where to from here?
    Appendix 1. Timeline/cast of characters
    Appendix 2. 1925 Report Final Resolutions
    Appendix 3. 1921 ICC Resolutions
    Appendix 4. 1922 ICC Resolutions
    Appendix 5. 1923 ICC Resolutions
    Appendix 6. 1924 ICC Resolutions
    Appendix 7. 1925 ICC Resolutions
    Appendix 8. 1927 ICC Resolutions
    Appendix 9. 1927 Draft Model Convention
    Appendix 10. 1925 UK Finance Act
    Appendix 11. Thompson Art 10 Proposal
    Appendix 12. USSR Art 5 Proposal
    Appendix 13. USSR Art 10 and 11 Proposals
    Appendix 14. Dorn and Borduge Draft Convention
    Appendix 15. Thompson Draft Convention
    Appendix 16. Adams Draft Convention
    Appendix 17. Draft Convention IA
    Appendix 18. Draft Convention IB
    Appendix 19. Draft Convention IB Commentary
    Appendix 20. Draft Convention IC
    Appendix 21. Draft Convention IC Commentary
    Bibliography
    Index.

  • Author

    Sunita Jogarajan, University of Melbourne
    Sunita Jogarajan is Associate Professor in the Melbourne Law School, University of Melbourne. She has published in the Oxford Journal of Legal Studies, British Tax Review and World Tax Journal.

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