Overview

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.

Full Product Details

Author:   Sunita Jogarajan (University of Melbourne)
Publisher:   Cambridge University Press
Imprint:   Cambridge University Press
Dimensions:   Width: 15.70cm , Height: 2.00cm , Length: 23.50cm
Weight:   0.700kg
ISBN:  

9781108421447

ISBN 10:   110842144
Pages:   352
Publication Date:   10 May 2018
Audience:   Professional and scholarly ,  Professional & Vocational
Format:   Hardback
Publisher's Status:   Active
Availability:   Available To Order  
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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.

Reviews

'This book gives a vivid picture of the negotiations that will be of interest to those having a wider interest in international taxation. It should be compulsory reading for those developing policy in this field. It is, unusually, a tax book that will never become out of date.' John Avery Jones, British Tax Review

Author Information

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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