Non-discrimination in Tax Treaty Law and World Trade Law is the first comprehensive review of non-discrimination rules in World Trade Organization (WTO) and tax law, combining critical commentary on case law with proposals for an innovative new concept for solving cases of discrimination in tax treaty law.
Non-discrimination is a central obligation under both tax treaty law and trade law, but its application raises complex challenges in the Base Erosion and Profit Shifting era. However, in seeking to strike a balance between national and international interests, its application differs in the two areas of practice. This deeply researched and authoritative work explains the policy issues and how non-discrimination analysis works.
What’s in this book:
Among the practical issues affecting non-discrimination examined in detail are the following:
How this will help you:
Drawing on over a half-century of case law in both areas of practice, this comprehensive study of the non-discrimination rules under WTO law and international tax law will be invaluable in systematically solving cases of tax discrimination under Article 24 of the OECD Model and putting forward arguments at any stage of a WTO analysis. Policymakers will benefit from the author’s clear explanation of how national law should comply with international obligations. Also, taxpayers’ advisers will proceed confidently in claims of tax treaty discrimination, and academics will discover an incomparable overview and analysis of anti-discrimination rules in international trade law and double taxation conventions.