内容

目次

• The legal framework: international law • The legal framework: European Union law • The legal framework: United Kingdom law • Interpretation of tax treaties • Scope of tax treaties: taxes covered and territorial scope • Access to treaty benefits: personality, fiscal domicile and nationality • Permanent establishment • Distributive provisions of income tax treaties • Business profits • Income from property • Employment and pensions • Capital gains • Other income and miscellaneous cases • Treaties and European tax directives • Elimination of double taxation • Non-discrimination • Treaty shopping and other avoidance • Administration of tax treaties • Disputes and mutual agreement procedure • EU arbitration convention • International administrative cooperation