Roy Rohatgi on International Taxation is an introductory text for practitioners and students of international tax law. For many years, this two-volume title has enjoyed a reputation as one of the leading handbooks in this complex area of taxation.
With the latest rewrite of this seminal work, the authors provide in-depth treatment of the key topics in international tax, building up from detailed explanation of the basic concepts, all the way to solid analysis of the complex transactional issues.
Volume 1, Principles, lays the foundation for this two-volume set. It examines international taxation through the prism of domestic law, explaining the conflicts of laws that give rise to issues seeking resolution in the international arena. This volume also introduces the reader to the world of tax treaties, crucially focusing on income and capital tax treaties, as well as on the main treaties that concern the administration and collection of taxes in the international sphere.
In its analysis of income and capital tax treaties, this book takes the OECD Model Convention as the starting point and enriches the discussion with examples from real-life treaties, as well as by contrasting provisions from other Model treaties. The book is rounded out by a generous analysis of jurisprudence from all over the world. What the reader gets is a thoroughly researched handbook, explaining the key principles of international taxation, buttressed with real-world practice and written with practical application in mind.
This volume is one of the first authoritative works to include analysis of the provisions of the updated OECD Model Convention (2017) and UN Model Convention (2017).
Contributors: Sophia Akhtar, Vanessa Arruda Ferreira, Victor Chew, Wooje Choi, Giulia Gallo, Francesco De Lillo, Neha Mohan, Belema Obuoforibo, Ola Ostaszewska, Rachel Saw, Ruxandra Vlasceanu.
Reprinted by Taxmann in India by arrangement with the IBFD for sale in India, Sri Lanka, Bangladesh and Pakistan. The book may not be exported for sale outside the above named countries. Sales to other countries should be directed to IBFD www.ibfd.org
Contents
Chapter 1: Introduction
Chapter 2: How Double Taxation Arises ? The Role of Domestic Tax Systems
Chapter 3: Double Taxation Relief
Chapter 4: Tax Treaties and Their Role in International Taxation
Chapter 5: Model Conventions
Chapter 6: Multilateral Tax Agreements
Chapter 7: Treaties on Administrative Assistance
Chapter 8: Structure of Tax Treaties
Chapter 9: Scope of Tax Treaties ? Persons Covered, Taxes Covered
Chapter 10: Residence
Chapter 11: Active Income of Companies
Chapter 12: Active Income of Individuals
Chapter 13: Passive Income
Chapter 14: Taxation of Income from Immovable Property
Chapter 15: Capital Gains
Chapter 16: Other Distributive Rules
Chapter 17: Methods for Elimination of Double Taxation
Chapter 18: Entitlement to Treaty Benefi ts
Chapter 19: Prohibition of Discrimination
Chapter 20: Administrative Provisions
Chapter 21: The Vienna Convention on the Law of Treaties
Chapter 22: Role of the OECD Commentaries
Chapter 23: The Role of the OECD Multilateral Instrument
Chapter 24: Interaction between Domestic Law and Tax Treaties
Chapter 25: Lifecycle of Tax Treaties
Chapter 26: Tax Treaties and Dispute Resolution
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