Under Action 14, jurisdictions have committed to implement a minimum standard to strengthen the effectiveness and efficiency of the mutual agreement procedure (MAP). The MAP is included in Article 25 of the OECD Model Tax Convention and commits countries to endeavour to resolve disputes related...

This book chapter suggests that nineteenth-century tax treaties and federal laws of German speaking European countries that concerned double taxation established the basis from which tax treaties and model conventions developed in the following centuries. The content of these German tax treaties...

The article deals with the interesting issue of the tax treaty qualification problems arising in hybrid financial instruments and structures. The need to fit the great diversity of instruments and legal, economic and accounting trends attached to them into the closed range of treaty income...

I analyze the effects of profit taxation on the financing decision of corporate acquisitions. The deductibility of interest expenses from the corporate tax base creates an incentive for acquiring companies to finance a takeover with debt. Regarding the particular decision how to finance the...