Double Tax Treaties: An Introduction

Reuven S. Avi-Yonah

in The Effect of Treaties on Foreign Direct Investment

Published in print April 2009 | ISBN: 9780195388534
Published online May 2009 | e-ISBN: 9780199855322 | DOI:
 Double Tax Treaties: An Introduction

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This chapter discusses double taxation treaties (DTTs). The existing network of more than 2,500 bilateral DTTs represents an important part of international law. Current DTTs are all based on two models, the Organization for Economic Co-operation and Development (OECD) and United Nations (UN) model DTTs, which in turn are based on models developed by the League of Nations between 1927 and 1946. All DTTs are remarkably similar in the topics covered (even the order of articles are always the same) and in their language. About 75% of the actual words of any given DTT are identical with the words of any other DTT. Thus, the DTT network is the most important element of the international tax regime, that is, the generally applicable rules governing income taxation of cross-border transactions.

Keywords: DTTs; international law; international taxation; income taxation; bilateral DTTs

Chapter.  4185 words. 

Subjects: Public International Law

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