Includes bibliographical references (pages 399-400) and index.
General -- The three qualifying questions -- The allocation rules -- Restrictions on the availability of DTA benefits -- Avoiding double tax -- Non-discrimination -- Procedures -- The reconstructed alternative Australia/UK DTA -- Some leading DTA cases -- Double taxation agreements table.
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The book explains how double agreements are designed and structured. It provides a framework to understand the way in which such agreements are drafted and illustrates, using the UK/Australia agreement as a model, how drafting can be refined to better reflect the conceptual underpinnings of the agreements. Key cases and actual double taxation agreements (including UK/USA, Australia/USA, China/Germany, and China/France) are reviewed and analysed.