International tax treaties law

The book provides a systematic analysis of international tax treaties, with reference to the OECD Model Tax Convention on Income and on Capital (the OECD Model), describing the amendments made in 2017 and 2019 to the OECD Model and its Commentary, which resulted from the Action Plan developed by the OECD 2013-2021. After an introduction on the taxing powers of States, international double taxation and the structure of the OECD Model, the book analyzes the following topics: the personal scope of tax treaties, “permanent establishment” and business profits, investment income (dividends, interest, royalties), and other categories of income, including income from personal services. The book concludes with a discussion of the provisions of the OECD Model concerning the non-discrimination principle in tax treaties, the mutual agreement procedure and exchange of information.