返回Google圖書搜尋

OECD (2020) Public Consultation on the Platform for Collaboration on Tax (PCT)'s Draft Toolkit on Tax Treaty Negotiations

其他書名	Comments by B. Michel and T. Falcao
出版	SSRN, 2022
URL	http://books.google.com.hk/books?id=hQffzwEACAAJ&hl=&source=gbs_api

註釋The paper provides a number of comments on the Platform on Collaboration on Tax (PCT)'s draft Toolkit on Tax Treaty Negotiations. This submission is comprised of two parts. The first part discusses the terminology currently being employed in the PCT Toolkit on Tax Treaty negotiation, and suggests alternative language to address the variable issues arising out of the different “profiles” of “developing countries.” The second part suggests an extension in the scope of the PCT Toolkit, to encompass not just the negotiation of tax treaties, but also its application by national tax officials and tax courts, and eventual renegotiation or termination in light of the modernization of rules, or of external third party advise. This is because an essential feature of having enforceable tax treaties is being able to keep them “alive” and current following the latest developments in the application of international tax rules.The public consultation document is available at: https://www.oecd.org/tax/treaties/the-platform-for-collaboration-on-tax-invites-public-comments-on-the-draft-toolkit-on-tax-treaty-negotiations.htm.