The advantages and disadvantages of multilateral tax treaties have been debated for many years. Although some multilateral tax treaties have been concluded at regional level, the concept has not yet gained wide acceptance. Recently it has become clear, however, that diverging provisions in bilateral tax treaties lead to undesired consequences. Tax administrations expend considerable energy combatting tax structures devised by taxpayers and their advisers, in an attempt to use these differences to their advantage. This engages the resources of both enterprises and tax authorities without their efforts being useful from an economic point of view. This book is the result of a research project conducted at the Department for Austrian and International Tax Law at the University of Economics and Business Administration in Vienna. The project's aim was to produce a draft multilateral tax treaty modelled on the OECD Model Income Tax Convention, whilst examining in detail difficulties that arise in connection with the multilateralization of the OECD Model.
