Reference : Tackling Complex Discrimination in International Taxation
Scientific journals : Article
Law, criminology & political science : Tax law
http://hdl.handle.net/10993/10144
Tackling Complex Discrimination in International Taxation
English
Haslehner, Werner mailto [London School of Economics - LSE > Law Department]
2012
British Tax Review
Sweet & Maxwell
5
596-622
Yes
International
0007-1870
[en] Non-discrimination ; International taxation ; Art 24 OECD
[en] The article examines instances of "complex discrimination" in tax laws and proposes a solution for these cases on the basis of a normative understanding of the common non-discrimination provision in bilateral tax treaties as a specific equality standard, which suggets the combined sequential application of the various non-discrimination rules typically contained in that provision. The result of this approach is a readily available solution for taxpayers who are subjected to 'complex' forms of discrimination that would not otherwise appear to be addressed in Article 24 of the OECD Model Tax Convention (and the tax treaties based on this model), without the need to amend the existing legal framework.
Researchers ; Professionals
http://hdl.handle.net/10993/10144

File(s) associated to this reference

Fulltext file(s):

FileCommentaryVersionSizeAccess
Limited access
BTR 2012, 596 Offprint.pdfPublisher postprint1.12 MBRequest a copy

Bookmark and Share SFX Query

All documents in ORBilu are protected by a user license.