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Multilingual Texts and Interpretation of Tax Treaties and EC Tax Law

Author: Guglielmo Maisto (jurist.)

Publisher: IBFD

Published: 2005

Total Pages: 375

ISBN-13: 9076078823

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The book identifies linguistic issues arising in bilateral income tax conventions and presents an in-dept analysis of tax treaty policies on multilingualism and the administrative practice and case law on the issues raised by the translation of treaties. Individual country surveys discuss the use of legal concepts, including those that do not exist in the legal system of one of the two contracting states and the way such concepts should be interpreted in such state (e.g. trust). Further, the use of concepts in one state that are similar but not identical to a treaty concept that is well known only in the other state (e.g. droit d'auteur vs copyright) are presented. The book also includes special reports on multilingual issues under both art. 33 of the Vienna Convention and art. 3(2) of the OECD Model Convention and Commentaries. Finally, a specific chapter is devoted to the EU law aspects and a review of the jurisprudence of the European Court of Justice (ECJ).

Book Synopsis Multilingual Texts and Interpretation of Tax Treaties and EC Tax Law by : Guglielmo Maisto (jurist.)

Download or read book Multilingual Texts and Interpretation of Tax Treaties and EC Tax Law written by Guglielmo Maisto (jurist.) and published by IBFD. This book was released on 2005 with total page 375 pages. Available in PDF, EPUB and Kindle. Book excerpt: The book identifies linguistic issues arising in bilateral income tax conventions and presents an in-dept analysis of tax treaty policies on multilingualism and the administrative practice and case law on the issues raised by the translation of treaties. Individual country surveys discuss the use of legal concepts, including those that do not exist in the legal system of one of the two contracting states and the way such concepts should be interpreted in such state (e.g. trust). Further, the use of concepts in one state that are similar but not identical to a treaty concept that is well known only in the other state (e.g. droit d'auteur vs copyright) are presented. The book also includes special reports on multilingual issues under both art. 33 of the Vienna Convention and art. 3(2) of the OECD Model Convention and Commentaries. Finally, a specific chapter is devoted to the EU law aspects and a review of the jurisprudence of the European Court of Justice (ECJ).

Multilingual Tax Treaties

Author: Paolo Arginelli

Publisher:

Published: 2015

Total Pages: 784

ISBN-13: 9789087223212

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Tax treaties are generally concluded in multiple authentic languages. This practice adds a factor that is to be taken into account when such treaties are interpreted and, in some cases, increases the complexity of that task.0 This book aims at identifying and clarifying the most common issues emerging in the interpretation of multilingual tax treaties. It suggests how an interpreter should tackle and disentangle such issues under public international law, with emphasis on the arguments to be used and the elements and items of evidence the interpreter can rely on to support his construction of the treaty. The issues of interpretation of multilingual treaties dealt with in this study may be divided between those of a general nature and those specific to multilingual tax treaties. Particular attention is paid to the interaction between the renvoi to the contracting states’ domestic laws, encompassed in article 3(2) of OECD Model-based tax treaties, and the linguistic aspects of those treaties, including their multilingualism.

Book Synopsis Multilingual Tax Treaties by : Paolo Arginelli

Download or read book Multilingual Tax Treaties written by Paolo Arginelli and published by . This book was released on 2015 with total page 784 pages. Available in PDF, EPUB and Kindle. Book excerpt: Tax treaties are generally concluded in multiple authentic languages. This practice adds a factor that is to be taken into account when such treaties are interpreted and, in some cases, increases the complexity of that task.0 This book aims at identifying and clarifying the most common issues emerging in the interpretation of multilingual tax treaties. It suggests how an interpreter should tackle and disentangle such issues under public international law, with emphasis on the arguments to be used and the elements and items of evidence the interpreter can rely on to support his construction of the treaty. The issues of interpretation of multilingual treaties dealt with in this study may be divided between those of a general nature and those specific to multilingual tax treaties. Particular attention is paid to the interaction between the renvoi to the contracting states’ domestic laws, encompassed in article 3(2) of OECD Model-based tax treaties, and the linguistic aspects of those treaties, including their multilingualism.

The Interpretation of Multilingual Tax Treaties

Author: Paolo Arginelli

Publisher:

Published: 2013

Total Pages: 677

ISBN-13: 9789087282011

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The purpose of this study is to single out and clarify the most common types of issues emerging in the interpretation of multilingual tax treaties (i.e. tax treaties authenticated in two or more languages). Its purpose is also to suggest how the interpreter should tackle and disentangle such issues under public international law, with a particular emphasis on the kinds of arguments he should use and the kinds of elements and items of evidence he should rely upon in order to support his construction of the treaty.

Book Synopsis The Interpretation of Multilingual Tax Treaties by : Paolo Arginelli

Download or read book The Interpretation of Multilingual Tax Treaties written by Paolo Arginelli and published by . This book was released on 2013 with total page 677 pages. Available in PDF, EPUB and Kindle. Book excerpt: The purpose of this study is to single out and clarify the most common types of issues emerging in the interpretation of multilingual tax treaties (i.e. tax treaties authenticated in two or more languages). Its purpose is also to suggest how the interpreter should tackle and disentangle such issues under public international law, with a particular emphasis on the kinds of arguments he should use and the kinds of elements and items of evidence he should rely upon in order to support his construction of the treaty.

The Interpretation of Plurilingual Tax Treaties

Author: Richard Xenophon Resch

Publisher: Tredition Gmbh

Published: 2018-12-14

Total Pages: 516

ISBN-13: 9783743902084

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RICHARD X. RESCH THE INTERPRETATION OF PLURILINGUAL TAX TREATIES Based on an analysis of 3,844 tax treaties, the Vienna Convention on the Law of Treaties and its Commentaries (VCLT), and case law of various domestic and international courts. The current orthodoxy maintains that courts are not required to compare all language texts of a plurilingual treaty but may rely on a single one for cases of routine interpretation. This view is erroneous, in violation of the VCLT, and the source of treaty misapplication; taxpayers are ill-advised to pay attention only to the text in their own language. In daily practice, the issue is of great relevance: almost three-quarters of the well over 3,000 concluded tax treaties are plurilingual. The BEPS MLI escalates complexity because it modifies a large number of treaties having texts in various languages. This study aims to (1) help diminish treaty misapplication through abandonment of the current orthodoxy, (2) show that sole reliance on prevailing texts is available as a pragmatic alternative in line with the VCLT, and (3) provide policy recommendations how residual cases may be eliminated. To support these goals, this study seeks to provide conclusive arguments and useful data to policy makers, treaty negotiators, judges, practitioners, and scholars. Its analysis of all tax treaty final clauses is intended to help both taxpayers and courts interpreting tax treaties in practice. The general arguments presented in this book are however not limited to tax treaties, since similar issues play a role in the interpretation of other treaties, for example, in the field of foreign investment regulation.

Book Synopsis The Interpretation of Plurilingual Tax Treaties by : Richard Xenophon Resch

Download or read book The Interpretation of Plurilingual Tax Treaties written by Richard Xenophon Resch and published by Tredition Gmbh. This book was released on 2018-12-14 with total page 516 pages. Available in PDF, EPUB and Kindle. Book excerpt: RICHARD X. RESCH THE INTERPRETATION OF PLURILINGUAL TAX TREATIES Based on an analysis of 3,844 tax treaties, the Vienna Convention on the Law of Treaties and its Commentaries (VCLT), and case law of various domestic and international courts. The current orthodoxy maintains that courts are not required to compare all language texts of a plurilingual treaty but may rely on a single one for cases of routine interpretation. This view is erroneous, in violation of the VCLT, and the source of treaty misapplication; taxpayers are ill-advised to pay attention only to the text in their own language. In daily practice, the issue is of great relevance: almost three-quarters of the well over 3,000 concluded tax treaties are plurilingual. The BEPS MLI escalates complexity because it modifies a large number of treaties having texts in various languages. This study aims to (1) help diminish treaty misapplication through abandonment of the current orthodoxy, (2) show that sole reliance on prevailing texts is available as a pragmatic alternative in line with the VCLT, and (3) provide policy recommendations how residual cases may be eliminated. To support these goals, this study seeks to provide conclusive arguments and useful data to policy makers, treaty negotiators, judges, practitioners, and scholars. Its analysis of all tax treaty final clauses is intended to help both taxpayers and courts interpreting tax treaties in practice. The general arguments presented in this book are however not limited to tax treaties, since similar issues play a role in the interpretation of other treaties, for example, in the field of foreign investment regulation.

International Tax Treaties of All Nations

Author: Walter H. Diamond

Publisher:

Published: 1975

Total Pages:

ISBN-13:

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Book Synopsis International Tax Treaties of All Nations by : Walter H. Diamond

Download or read book International Tax Treaties of All Nations written by Walter H. Diamond and published by . This book was released on 1975 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt:

Authentic Languages and Official Translations of the Multilateral Instrument and Covered Tax Agreements

Author: Josef Schuch

Publisher:

Published: 2019

Total Pages: 27

ISBN-13:

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The authentic languages of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (commonly referred to as the multilateral instrument, MLI) are French and English, both languages being equally authentic. The MLI modifies hundreds of bilateral double taxation conventions (hereinafter 'tax treaties'). These tax treaties have their own authentic languages, often the official languages of the contracting states, which might be different than French and English. This leads to complicated situations. For example Austria and Italy have indicated that they wish to modify the 1981 Austria-Italy tax treaty by the MLI. The authentic languages of that tax treaty are German and Italian. As a consequence, when one wants to consult the Austria-Italy tax treaty as modified by the MLI, the original provisions of the tax treaty are authentic in German and Italian, whereas the provisions modified by the MLI are authentic in French and English. As a result, it is possible that some paragraphs of a certain provision of the tax treaty are authentic only in German and Italian, while some other paragraphs of that provision as modified by the MLI are authentic only in French and English. Immediately questions arise as to how one should interpret those tax treaties which do not have French and English as their authentic languages and which are modified by the MLI, and how interpretation issues related to different authentic language versions should be resolved. This contribution will provide answers to these questions.

Book Synopsis Authentic Languages and Official Translations of the Multilateral Instrument and Covered Tax Agreements by : Josef Schuch

Download or read book Authentic Languages and Official Translations of the Multilateral Instrument and Covered Tax Agreements written by Josef Schuch and published by . This book was released on 2019 with total page 27 pages. Available in PDF, EPUB and Kindle. Book excerpt: The authentic languages of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (commonly referred to as the multilateral instrument, MLI) are French and English, both languages being equally authentic. The MLI modifies hundreds of bilateral double taxation conventions (hereinafter 'tax treaties'). These tax treaties have their own authentic languages, often the official languages of the contracting states, which might be different than French and English. This leads to complicated situations. For example Austria and Italy have indicated that they wish to modify the 1981 Austria-Italy tax treaty by the MLI. The authentic languages of that tax treaty are German and Italian. As a consequence, when one wants to consult the Austria-Italy tax treaty as modified by the MLI, the original provisions of the tax treaty are authentic in German and Italian, whereas the provisions modified by the MLI are authentic in French and English. As a result, it is possible that some paragraphs of a certain provision of the tax treaty are authentic only in German and Italian, while some other paragraphs of that provision as modified by the MLI are authentic only in French and English. Immediately questions arise as to how one should interpret those tax treaties which do not have French and English as their authentic languages and which are modified by the MLI, and how interpretation issues related to different authentic language versions should be resolved. This contribution will provide answers to these questions.

International Tax Treaties of All Nations

Author: Walter H. Diamond

Publisher:

Published: 1976

Total Pages: 512

ISBN-13:

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Book Synopsis International Tax Treaties of All Nations by : Walter H. Diamond

Download or read book International Tax Treaties of All Nations written by Walter H. Diamond and published by . This book was released on 1976 with total page 512 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Interpretation of Tax Treaties under International Law

Author: F. A. Engelen

Publisher: IBFD

Published: 2004

Total Pages: 615

ISBN-13: 9076078726

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This publication considers the interpretation of tax treaties primarily from the standpoint of public international law. The principal purpose of this study is to analyse and discuss the rules and principles of international law relevant to the interpretation of treaties in general, and their application to tax treaties in particular. The rules of international law enshrined in articles 31, 32 and 33 of the Vienna Convention on the Law of Treaties are therefore central to this study. Where appropriate, reference is made to the jurisprudence of the International Court of Justice, and to the law and procedure of other international court and tribunals. Considers also the extent to which the relevant rules and principles of international law are binding on domestic court and taxpayers. The importance of international law for the purpose of the interpretation of tax treaties is illustrated by a number of leading cases decided by the Dutch Supreme Court (Hoge Raad).

Book Synopsis Interpretation of Tax Treaties under International Law by : F. A. Engelen

Download or read book Interpretation of Tax Treaties under International Law written by F. A. Engelen and published by IBFD. This book was released on 2004 with total page 615 pages. Available in PDF, EPUB and Kindle. Book excerpt: This publication considers the interpretation of tax treaties primarily from the standpoint of public international law. The principal purpose of this study is to analyse and discuss the rules and principles of international law relevant to the interpretation of treaties in general, and their application to tax treaties in particular. The rules of international law enshrined in articles 31, 32 and 33 of the Vienna Convention on the Law of Treaties are therefore central to this study. Where appropriate, reference is made to the jurisprudence of the International Court of Justice, and to the law and procedure of other international court and tribunals. Considers also the extent to which the relevant rules and principles of international law are binding on domestic court and taxpayers. The importance of international law for the purpose of the interpretation of tax treaties is illustrated by a number of leading cases decided by the Dutch Supreme Court (Hoge Raad).

International Tax Treaties of All Nations

Author: Walter H. Diamond

Publisher:

Published: 1975-01-01

Total Pages:

ISBN-13: 9780379007251

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Book Synopsis International Tax Treaties of All Nations by : Walter H. Diamond

Download or read book International Tax Treaties of All Nations written by Walter H. Diamond and published by . This book was released on 1975-01-01 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt:

Treaties 1616-1667

Author: Nations Unies

Publisher:

Published: 1992

Total Pages: 339

ISBN-13: 9780379007503

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Book Synopsis Treaties 1616-1667 by : Nations Unies

Download or read book Treaties 1616-1667 written by Nations Unies and published by . This book was released on 1992 with total page 339 pages. Available in PDF, EPUB and Kindle. Book excerpt: