Double Taxation and the League of Nations (Cambridge Tax Law Series)

Présentation de l'éditeur : "Modern-day tax treaties have their foundations in one of the three Model Tax Treaties developed by the League of Nations in 1928. Using previously unexplored archival material, Sunita Jogarajan provides the first in-depth examination of the development of the League's Models. This new research provides insights into questions such as the importance of double taxation versus tax evasion; the preference for source-taxation versus residence-taxation; the influence of theory and practice on the League's work; the development of bilateral rather than multilateral treaties; the influence of developing countries on the League's work; the role of Commentary in interpreting model tax treaties; and the influential factors and key individuals involved. A better understanding of the development of the original models will inform and help guide interpretation and reform of modern-day tax treaties. Additionally, this book will be of interest to scholars of international relations and the development of law at international organisations." Contents 6 Tables 9 Preface 10 Acknowledgements 11 Abbreviations 12 1 Introduction 14 2 Background 20 3 Personality, Politics, and Principles 35 4 The ICC and the Development of the 1928 Models 98 5 Turning Resolutions into Treaties 111 6 The Great Powers’ and the Development of the 1928 Models 180 7 One Beget Three 195 8 Lessons from History 256 Appendix 1 Timeline/Cast of Characters 270 Appendix 2 1925 Report Final Resolutions 283 Appendix 3 1921 ICC Resolutions 287 Appendix 4 1922 ICC Resolutions 289 Appendix 5 1923 ICC Resolutions 291 Appendix 6 1924 ICC Resolutions 293 Appendix 7 1925 ICC Resolutions 296 Appendix 8 1927 ICC Resolutions 299 Appendix 9 1927 Draft Model Convention 300 Appendix 10 1925 UK Finance Act 311 Appendix 11 Thompson Article 10 Proposal 312 Appendix 12 USSR Article 5 Proposal 313 Appendix 13 USSR Articles 10 and 11 Proposals 315 Appendix 14 Dorn and Borduge Draft Convention 316 Appendix 15 Thompson Draft Convention 319 Appendix 16 Adams Draft Convention 321 Appendix 17 Draft Convention Ia 324 Appendix 18 Draft Convention Ib 328 Appendix 19 Draft Convention Ib Commentary 331 Appendix 20 Draft Convention Ic 333 Appendix 21 Draft Convention Ic Commentary 336 Bibliography 338 Index 345 DOUBLE,TAXATION,AND,THE,LEAGUE,OF,NATIONS Double Taxation And The League Of Nations Modern-day Tax Treaties Have Their Foundations In One Of The Three Model Tax Treaties Developed By The League Of Nations In 1928. Using Previously Unexplored Archival Material, Sunita Jogarajan Provides The First In-depth Examination Of The Development Of The League's Models. This New Research Provides Insights Into Questions Such As The Importance Of Double Taxation Vs Tax Evasion; The Preference For Source-taxation Vs Residence-taxation; The Influence Of Theory And Practice On The League's Work; The Development Of Bilateral Rather Than Multilateral Treaties; The Influence Of Developing Countries On The League's Work; The Role Of Commentary In Interpreting Model Tax Treaties; And The Influential Factors And Key Individuals Involved. A Better Understanding Of The Development Of The Original Models Will Inform And Help Guide Interpretation And Reform Of Modern-day Tax Treaties. Additionally, This Book Will Be Of Interest To Scholars Of International Relations And The Development Of Law At International Organisations-- Sunita Jogarajan. Includes Bibliographical References And Index. "Double Taxation and the League of Nations Modern-day tax treaties have their foundations in one of the three Model Tax Treaties developed by the League of Nations in 1928. Using previously unexplored archival material, Sunita Jogarajan provides the first in-depth examination of the development of the League's Models. This new research provides insights into questions such as the importance of double taxation vs tax evasion; the preference for source-taxation vs residence-taxation; the influence of theory and practice on the League's work; the development of bilateral rather than multilateral treaties; the influence of developing countries on the League's work; the role of Commentary in interpreting model tax treaties; and the influential factors and key individuals involved. A better understanding of the development of the original models will inform and help guide interpretation and reform of modern-day tax treaties. Additionally, this book will be of interest to scholars of international relations and the development of law at international organisations"-- Provided by publisher Présentation de l'éditeur : "Modern-day tax treaties have their foundations in one of the three Model Tax Treaties developed by the League of Nations in 1928. Using previously unexplored archival material, Sunita Jogarajan provides the first in-depth examination of the development of the League's Models. This new research provides insights into questions such as the importance of double taxation versus tax evasion; the preference for source-taxation versus residence-taxation; the influence of theory and practice on the League's work; the development of bilateral rather than multilateral treaties; the influence of developing countries on the League's work; the role of Commentary in interpreting model tax treaties; and the influential factors and key individuals involved. A better understanding of the development of the original models will inform and help guide interpretation and reform of modern-day tax treaties. Additionally, this book will be of interest to scholars of international relations and the development of law at international organisations."