内容

目次

1. The legal framework: International law 2. The legal framework: European Union law 3. The legal framework: United Kingdom law 4. Interpretation of tax treaties 5. Scope of tax treaties: taxes covered and territorial scope 6. Access to treaty benefits: personality, fiscal domicile and nationality 7. Permanent establishment 8. Distributive provisions of income tax treaties 9. Business profits 10. Income from property 11. Employment and pensions 12. Capital gains 13. Other income and miscellaneous cases 14. Treaties and European tax directives 15. Elimination of double taxation 16. Non-discrimination 17. Treaty shopping and other avoidance 18. Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS 19. Administration of tax treaties 20. Disputes and mutual agreement procedure 21. EU international tax dispute resolution directive and arbitration convention 22. International administrative cooperation