A Multilateral Agreement for International Taxation: Designing an instrument to modernise international tax law

• Main Author: D.M. Broekhuijsen
• Language: English
• Published: DANS Data Station Social Sciences and Humanities 2016
• Subjects: Law; tax treaties; international tax law; tax treaty case law; OECD Commentary; Iceland
• Online Access: https://doi.org/10.17026/dans-x22-k8wh

Appendix A includes an analysis of conclusion and amendment dates of tax treaties. It is part of the thesis "A Multilateral Agreement for International Taxation: Designing an instrument to modernise international tax law.' The point of Appendix A is to calculate the average time tax treaties are updated. Data from the IBFD’s tax treaty database on tax treaties, in force on 1 January 2013, was used to calculate the average time (i.e., the ‘estimated mean’) in which an OECD-member country’s tax treaty was updated. In the database, the date of conclusion of each selected tax treaty was coded, as well as the date of: (1) any new bilateral tax treaty concluded within the same tax treaty relationship; (2) a protocol to a treaty or (3) an exchange of notes or any other mutual agreement, provided that this agreement changed the wording of the tax treaty in question. Only the treaties of the founding states of the OECD were taken into account. These are: the Republic of Austria, the Kingdom of Belgium, the Dominion of Canada, the Kingdom of Denmark, the French Republic, the Federal Republic of Germany, the Kingdom of Greece, the Republic of Iceland, the Republic of Ireland, the Italian Republic, the Grand Duchy of Luxembourg, the Kingdom of the Netherlands, the Kingdom of Norway, the Portuguese Republic, the Kingdom of Spain, the Kingdom of Sweden, the Swiss Confederation, the Turkish Republic, the United Kingdom of Great Britain and Northern Ireland, and the United States of America. The count includes tax treaties of these countries with non-OECD member countries. In counting the amendments to tax treaties in force, terminated treaties which have not been followed up by a new treaty, abandoned treaties as well as treaties that were not ratified before 1-1-2013, were excluded. Moreover, all pre-war (1940) treaties were not considered. --- Appendix B includes the tax treaty case law analysis to the thesis "A Multilateral Agreement for International Taxation, Designing an instrument to modernise international tax law". ...