ITTN - List of Contents, and sample pages

Introduction

• Outline
• Background development of tax treaties
• The OECD Model
• United Nations Model
• Other Models
• Expansion of Commentary on OECD and UN Models
• Additional OECD Commentary
• Additional UN Commentary
• Multilateral Conventions
• Convergence of tax systems
• Impact of the Model on the Negotiation of Bilateral Treaties

General Issues

• Oil and Gas in Tax Treaties
• Triangular Situations
• The Impact of Electronic Commerce
• Curbing Harmful Tax Practices
• Controlled Foreign Company legislation
• Partnerships
• The European Court of Justice

Text and Discussion of the Model Articles (sample pages)

Please note that not all the hyperlinks work, as these sample pages are just a small part of the complete work.

• Text of OECD Model Article 12
• Discussion of Article 12
• Model Article 12 Summary
• Meaning of the symbols for Article 12
• Germany page
  • by article
  • by treaty
  • treaty dates
• Germany Article 12 (Royalties) page