THE IMPACT OF THE OECD AND UN MODEL CONVENTIONS ON BILATERAL TAX TREATIESPDF|Epub|txt|kindle电子书版本网盘下载

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General report1

Ⅰ The relevance of the OECD and UN Model Conventions and their Commentaries for the interpretation of tax treaties4

Ⅱ The personal and material scope of the tax treaties8

Ⅲ Business profits and income from other independent activities12

Ⅳ Passive income17

Ⅴ Income from employment and other dependent activities23

Ⅵ Methods for relieving double taxation28

Ⅶ The non-discrimination principle30

Ⅷ The mutual agreement procedure and international mutual assistance in tax matters32

1 Argentina37

1.1 The relevance of the OECD and UN Model Conventions and their Commentaries for the interpretation of Argentine tax treaties37

1.2 Personal and material scope of the tax treaties43

1.3 Business profits and other independent activities45

1.4 Dividends， interest， royalties and capital gains51

1.5 Employment and other dependent activities57

1.6 Methods to avoid double taxation60

1.7 Non-discrimination62

1.8 Mutual agreement， exchange of information and mutual assistance in the collection of taxes63

1.9 Conclusions66

2 Australia68

2.1 The relevance of the OECD and UN Model Conventions and their Commentaries for the interpretation of Australian tax treaties68

2.2 Personal and material scope of the tax treaties70

2.3 Business profits and other independent activities73

2.4 Dividends， interest， royalties and capital gains81

2.5 Employment and other dependent activities95

2.6 Methods to avoid double taxation99

2.7 Non-discrimination101

2.8 Mutual agreement， exchange of information and mutual assistance in the collection of taxes104

2.9 Conclusion108

3 Austria110

3.1 The relevance of the OECD and UN Model Conventions and their Commentaries for the interpretation of Austrian tax treaties110

3.2 Personal and material scope of the tax treaties112

3.3 Business profits and other independent activities115

3.4 Dividends， interest， royalties and capital gains122

3.5 Employment and other dependent activities127

3.6 Methods to avoid double taxation132

3.7 Non-discrimination135

3.8 Mutual agreement， exchange of information and mutual assistance in the collection of taxes138

4 Belgium142

4.1 The relevance of the OECD and UN Model Conventions and their Commentaries for the interpretation of Belgian tax treaties142

4.2 Personal and material scope of the tax treaties146

4.3 Business profits and other independent activities150

4.4 Dividends， interest， royalties and capital gains154

4.5 Employment and other dependent activities158

4.6 Methods to avoid double taxation： Article 23161

4.7 Non-discrimination： Article 24166

4.8 Mutual agreement， exchange of information and mutual assistance in the collection of taxes167

5 Brazil171

5.1 The relevance of the OECD and UN Model Conventions and their Commentaries on the interpretation of Brazilian tax treaties171

5.2 Personal and material scope of the tax treaties173

5.3 Business profits and other independent activities177

5.4 Dividends， interest， royalties and capital gains181

5.5 Employment and other dependent activities192

5.6 Methods to avoid double taxation： Article 23197

5.7 Non-discrimination： Article 24199

5.8 Mutual agreement， exchange of information and mutual assistance in the collection of taxes200

6 Canada203

6.1 The relevance of the OECD and UN Model Conventions and their Commentaries for the interpretation of Canadian tax treaties203

6.2 Personal and material scope of the tax treaties209

6.3 Business profits and other independent activities213

6.4 Dividends， interest， royalties and capital gains216

6.5 Employment and other dependent activities220

6.6 Methods to avoid double taxation： Article 23224

6.7 Non-discrimination： Article 24226

6.8 Mutual agreement， exchange of information and mutual assistance in the collection of taxes227

6.9 Conclusions231

7 Chile232

7.1 The relevance of the OECD and UN Model Conventions and their Commentaries for the interpretation of Chilean tax treaties232

7.2 Personal and material scope of the tax treaties235

7.3 Business profits and other independent activities238

7.4 Dividends， interest， royalties and capital gains245

7.5 Employment and other dependent activities250

7.6 Methods to avoid double taxation： Article 23253

7.7 Non-discrimination： Article 24254

7.8 Mutual agreement， exchange of information and mutual assistance in the collection of taxes257

8 China261

8.1 The relevance of the OECD and UN Model Conventions and their Commentaries for the interpretation of Chinese tax treaties261

8.2 Personal and material scope of the tax treaties： Articles 1， 2 and 4263

8.3 Business profits and other independent activities270

8.4 Dividends， interest， royalties and capital gains：Articles 10， 11， 12 and 13276

8.5 Employment and other dependent activities282

8.6 Methods to avoid double taxation： Article 23285

8.7 Non-discrimination： Article 24288

8.8 Mutual agreement and exchange of information290

9 Colombia294

9.1 The relevance of the OECD and UN Model Conventions and their Commentaries for the interpretation of Colombian tax treaties294

9.2 Personal and material scope of the tax treaties296

9.3 Business profits and other independent activities298

9.4 Dividends， interest， royalties and capital gains301

9.5 Employment and other dependent activities304

9.6 Methods to avoid double taxation305

9.7 Non-discrimination306

9.8 Mutual agreement， exchange of information and mutual assistance in the collection of taxes308

10 Croatia311

10.1 The relevance of the OECD and UN Model Conventions and their Commentaries for the interpretation of Croatian tax treaties311

10.2 Personal and material scope of the tax treaties313

10.3 Business profits and other independent activities316

10.4 Dividends， interest， royalties and capital gains320

10.5 Employment and other dependent activities321

10.6 Methods to avoid double taxation323

10.7 Non-discrimination323

10.8 Mutual agreement， exchange of information and mutual assistance in the collection of taxes324

11 The Czech Republic325

11.1 The relevance of the OECD and UN Model Conventions and their Commentaries for the interpretation of Czech tax treaties325

11.2 Personal and material scope of the tax treaties327

11.3 Business profits and other independent activities331

11.4 Dividends， interest， royalties and capital gains341

11.5 Employment and other dependent activities345

11.6 Methods to avoid double taxation348

11.7 Non-discrimination349

11.8 Mutual agreement， exchange of information and mutual assistance in the collection of taxes353

12 Estonia356

12.1 The relevance of the OECD and UN Model Conventions and their Commentaries for the interpretation of Estonian tax treaties356

12.2 Personal and material scope of the tax treaties358

12.3 Business profits and other independent activities364

12.4 Dividends， interest， royalties and capital gains369

12.5 Employment and other dependent activities372

12.6 Methods to avoid double taxation： Article 23378

12.7 Non-discrimination： Article 24379

12.8 Mutual agreement， exchange of information and mutual assistance in the collection of taxes383

13 Finland387

13.1 The relevance of the OECD and UN Model Conventions and their Commentaries for the interpretation of Finnish tax treaties387

13.2 Personal and material scope of the tax treaties390

13.3 Business profits and other independent activities394

13.4 Dividends， interest， royalties and capital gains397

13.5 Employment and other dependent activities404

13.6 Methods to avoid double taxation409

13.7 Non-discrimination414

13.8 Mutual agreement， exchange of information and mutual assistance in the collection of taxes416

14 France421

14.1 The relevance of the OECD and UN Model Conventions and their Commentaries for the interpretation of French tax treaties421

14.2 Personal and material scope of the tax treaties： Articles 1， 2 and 4430

14.3 Business profits and other independent activities441

14.4 Dividends， interest， royalties and capital gains445

14.5 Employment and other dependent activities453

14.6 Methods to avoid double taxation454

14.7 Non-discrimination459

14.8 Mutual agreement， exchange of information and mutual assistance in the collection of taxes463

15 Germany466

15.1 The importance of the OECD and UN Model Conventions and their Commentaries for the interpretation of German tax treaties466

15.2 Personal and material scope of the tax treaties471

15.3 Business profits and other independent activities476

15.4 Dividends， interest， royalties and capital gains483

15.5. Employment and other dependent activities489

15.6 Methods to avoid double taxation492

15.7 Non-discrimination495

15.8 Mutual agreement， exchange of information and mutual assistance in the collection of taxes496

16 Hong Kong501

16.1 The relevance of the OECD and UN Model Conventions and their Commentaries for the interpretation of Hong Kong tax treaties501

16.2 Personal and material scope of the tax treaties502

16.3 Business profits and other independent activities508

16.4 Dividends， interest， royalties and capital gains514

16.5 Employment and other dependent activities519

16.6 Methods to avoid double taxation524

16.7 Non-discrimination527

16.8 Mutual agreement， exchange of information and mutual assistance in the collection of taxes529

16.9 Concluding remarks530

17 Hungary532

17.1 The relevance of the OECD and UN Model Conventions and their Commentaries for the interpretation of Hungarian tax treaties532

17.2 Personal and material scope of the tax treaties534

17.3 Business profits and other independent activities539

17.4 Dividends， interest， royalties and capital gains544

17.5 Employment and other dependent activities545

17.6 Methods to avoid double taxation546

17.7 Non-discrimination546

17.8 Mutual agreement， exchange of information and mutual assistance in the collection of taxes547

18 India549

18.1 The relevance of the OECD and UN Model Conventions and their Commentaries for the interpretation of Indian tax treaties549

18.2 Personal and material scope of the tax treaties556

18.3 Business profits and other independent activities563

18.4 Dividends， interest， royalties and capital gains580

18.5 Employment and other dependent activities586

18.6 Methods to avoid double taxation： Article 23591

18.7 Non-discrimination： Article 24592

18.8 Mutual agreement， exchange of information andcollection of taxes595

19 Italy598

19.1 The relevance of the OECD and UN Model Conventions and their Commentaries for the interpretation of Italian tax treaties598

19.2 Personal and material scope of the tax treaties602

19.3 Business profits and other independent activities608

19.4 Dividends， interest， royalties and capital gains615

19.5 Employment and other dependent activities624

19.6 Methods to avoid double taxation： Article 23625

19.7 Non-discrimination： Article 24628

19.8 Mutual agreement， exchange of information and mutualassistance in the collection of taxes630

20 Lebanon633

20.1 The relevance of the OECD and the UN Model Conventions and their Commentaries for the interpretation of Lebanese tax treaties633

20.2 Personal and material scope of the tax treaties636

20.3 Business profits and other independent activities638

20.4 Dividends， interest， royalties and capital gains641

20.5 Employment and other dependent activities643

20.6 Methods to avoid double taxation645

20.7 Non-discrimination646

20.8 Mutual agreement， exchange of information and mutualassistance in the collection of taxes646

21 Liechtenstein649

21.1 The relevance of the OECD and the UN Model Conventions and their Commentaries for the interpretation of Liechtenstein tax treaties649

21.2 Personal and material scope of the tax treaties650

21.3 Business profits and other independent activities：Articles 5， 7， 8， 9， 16 and 17654

21.4 Dividends， interest， royalties and capital gains：Articles 10-13656

21.5 Employment and other dependent activities：Articles 15， 18， 19 and 20658

21.6 Methods to avoid double taxation： Article 23660

21.7 Non-discrimination： Article 24661

21.8 Mutual agreement， exchange of information and mutual assistance in the collection of taxes663

22 The Netherlands666

22.1 The relevance of the OECD and UN Model Conventions and their Commentaries for the interpretation of Dutch tax treaties666

22.2 Personal and material scope of the tax treaties670

22.3 Business profits and other independent activities679

22.4 Dividends， interest， royalties and capital gains700

22.5 Employment and other dependent activities707

22.6 Methods to avoid double taxation723

22.7 Non-discrimination726

22.8 Mutual agreement， exchange of information and mutual assistance in the collection of taxes728

23 New Zealand735

23.1 The relevance of the OECD Model Conventions and Commentaries for the interpretation of New Zealand tax treaties735

23.2 Personal and material scope of the tax treaties738

23.3 Business profits and other independent activities740

23.4 Dividends， interest， royalties and capital gains745

23.5 Employment and other dependent activities754

23.6 Methods to avoid double taxation： Article 23757

23.7 Non-discrimination： Article 24760

23.8 Mutual agreement， exchange of information and mutual assistance in the collection of taxes763

23.9 Conclusion767

24 Norway768

24.1 The relevance of the OECD and UN Model Conventions and their Commentaries for the interpretation of Norwegian tax treaties768

24.2 Personal and material scope of the tax treaties775

24.3 Business profuts and other independent activities782

24.4 Dividends， interest， royalties and capital gains784

24.5 Employment and other dependent activities788

24.6 Methods to avoid double taxation： Article 23789

24.7 Non-discrimination： Article 24791

24.8 Mutual agreement， exchange of information and mutual assistance in the collection of taxes792

25 Peru796

25.1 The relevance of the OECD and UN Model Conventions and their Commentaries for the interpretation of Peruvian tax treaties796

25.2 Personal and material scope of the tax treaties799

25.3 Business profits and other independent activities801

25.4 Dividends， interest， royalties and capital gains807

25.5 Employment and other dependent activities810

25.6 Methods to avoid double taxation： Article 23813

25.7 Non-discrimination814

25.8 Mutual agreement， exchange of information and mutual assistance in the collection of taxes816

26 Poland820

26.1 The relevance of the OECD and the UN Model Conventions and their Commentaries for the interpretation of Polish tax treaties820

26.2 Personal and material scope of the tax treaties822

26.3 Business profits and other independent activities827

26.4 Dividends， interest， royalties and capital gains836

26.5 Employment and other dependent activities841

26.6 Methods to avoid double taxation845

26.7 Non-discrimination848

26.8 Mutual agreement， exchange of information and mutual assistance in the cofiection of taxes850

27 Portugal855

27.1 The relevance of the OECD and the UN Model Conventions and their Commentaries for the interpretation of Portuguese tax treaties855

27.2 Personal and material scope of the tax treaties858

27.3 Business profits and other independent activities863

27.4 Dividends， interest， royalties and capital gains872

27.5 Employment and other dependent activities876

27.6 Methods to avoid double taxation880

27.7 Non-discrimination882

27.8 Mutual agreement， exchange of information and mutual assistance in the collection of taxes884

27.9 Concluding remarks887

28 Romania888

28.1 The relevance of the OECD and UN Model Conventions and their Commentaries for the interpretation of Romanian tax treaties888

28.2 Personal and material scope of the tax treaties892

28.3 Business profits and other independent activities895

28.4 Dividends， interest， royalties and capital gains903

28.5 Employment and other dependent activities909

28.6 Methods to avoid double taxation： Article 23911

28.7 Non-discrimination： Article 24912

28.8 Mutual agreement， exchange of information and mutual assistance in the collection of taxes913

29 The Russian Federation915

29.1 The relevance of the OECD and UN Model Conventions and their Commentaries for the interpretation of Russian tax treaties915

29.2 Personal and material scope of the tax treaties920

29.3 Business profits and other independent activities925

29.4 Dividends， interest， royalties and capital gains931

29.5 Employment and other dependent activities933

29.6 Methods to avoid double taxation935

29.7 Non-discrimination937

29.8 Mutual agreement， exchange of information and mutual assistance in the collection of taxes940

29.9 Conclusion943

30 Serbia944

30.1 The relevance of the OECD and UN Model Conventions and their Commentaries for the interpretation of Serbian tax treaties944

30.2 Personal and material scope of the tax treaties951

30.3 Business profits and other independent activities955

30.4 Dividends， interest， royalties and capital gains962

30.5 Employment and other dependent activities966

30.6 Methods to avoid double taxation969

30.7 Non-discrimination970

30.8 Mutual agreement， exchange of information and mutual assistance in the collection of taxes971

31 Slovakia973

31.1 The relevance of the OECD and UN Model Conventions and their Commentaries for the interpretation of Slovak tax treaties973

31.2 Personal and material scope of the tax treaties975

31.3 Business profits and other independent activities978

31.4 Dividends， interest， royalties and capital gains983

31.5 Employment and other dependent activities989

31.6 Methods to avoid double taxation： Article 23992

31.7 Non-discrimination： Article 24993

31.8 Mutual agreement， exchange of information and mutual assistance in the collection of taxes994

32 Slovenia998

32.1 The relevance of the OECD and UN Model Conventions and their Commentaries for the interpretation of Slovenian tax treaties998

32.2 Personal and material scope of the tax treaties1001

32.3 Business profits and other independent activities1003

32.4 Dividends， interest， royalties and capital gains1007

32.5. Employment and other dependent activities1015

32.6 Methods to avoid double taxation1018

32.7 Non-discrimination1019

32.8 Mutual agreement， exchange of information and mutual assistance in the collection of taxes1022

33 Spain1026

33.1 The relevance of the OECD and UN Model Conventions and their Commentaries for the interpretation of Spanish tax treaties1026

33.2 Personal and material scope of the tax treaties1031

33.3 Business profits and other independent activities1034

33.4 Dividends， interest， royalties and capital gains1039

33.5 Employment and other dependent activities1043

33.6 Methods to avoid double taxation1047

33.7 Non-discrimination1050

33.8 Mutual agreement， exchange of information and mutual assistance in the collection of taxes1053

34 Sweden1056

34.1 The relevance of the OECD and UN Model Conventions and their Commentaries for the interpretation of Swedish tax treaties1056

34.2 Personal and material scope of the tax treaties1060

34.3 Business profits and other independent activities1064

34.4 Dividends， interest and royalties and capital gains1067

34.5 Employment and other dependent activities1072

34.6 Methods to avoid double taxation1075

34.7 Non-discrimination1078

34.8 Mutual agreement， exchange of information and mutual assistance in the collection of taxes1079

35 Uganda1083

35.1 The relevance of the OECD and UN Model Conventions and their Commentaries for the interpretation of Ugandan tax treaties1083

35.2 Personal and material scope of the tax treaties1084

35.3 Business profits and other independent activities1088

35.4 Dividends， interest， royalties and capital gains1092

35.5 Employment and other dependent activities1094

35.6 Methods to avoid double taxation1096

35.7 Non-discrimination1097

35.8 Mutual agreement， exchange of information and mutual assistance in the collection of taxes1098

35.9 Conclusion 1099

36 The UK1101

36.1 The relevance of the OECD and UN Model Conventions and their Commentaries for the interpretation of UK tax treaties1101

36.2 Title and personal and material scope of the tax treaties1114

36.3 Business profits and other independent activities1121

36.4 Dividends， interest， royalties and capital gains1129

36.5 Employment and other dependent activities1134

36.6 Methods to avoid double taxation： Article 231137

36.7 Non-discrimination1138

36.8 Mutual agreement， exchange of information and mutualassistance in the collection of taxes1144

37 The USA1149

37.1 The relevance of the OECD and UN Model Conventions and their Commentaries for the interpretation of US tax treaties1149

37.2 Personal and material scope of the tax treaties1153

37.3 Business profits and other independent activities1158

37.4 Dividends， interest， royalties and capital gains1166

37.5 Employment and other dependent activities1170

37.6 Methods to avoid double taxation1171

37.7 Non-discrimination1174

37.8 Mutual agreement， exchange of information and mutual assistance in the collection of taxes1175

37.9 Conclusions1178

Index1180