Tax Treaty Policy and Development

The importance of tax treaty policy and its reaction to current issues in tax treaty application as well as tax planning are beyond doubt. Notwithstanding the fact that the world-wide tax treaty network in large part conforms to a model tax treaty, most tax treaties contain important deviations. These deviations are mostly caused by the special importance of a sector of the economy, particularities in the tax laws of the contracting states, or tax planning schemes revealed by tax administrations. Due to increasing integration of world-wide economies, such deviations gain more and more importance. At the same time, some states feel the need to not only make changes to the model treaties, but also to further deviate from the model in their negotiating position. Sometimes, a deviating negotiating position even results in a model of its own - e.g. the US-model.

This volume is dedicated to the analysis and comparison of tax treaty policies in different economic areas. It aims at highlighting differences in tax treaty policies within the economic areas and between the respective economic area and the rest of the world. Furthermore, this volume strives to show the funding of policies in the economic situation of the concerned states. An additional goal is to emphasize current issues in tax treaty application and resulting trends in the tax treaty policies of individual states as well as in the model treaties.