The use of OEEC-OECD historical documents in interpreting tax treaties / David A. WardA systems-based approach to tax treaties / Henri TorrioneTemporal aspects of tax treaties / Jacques SassevilleDouble taxation conventions and human rights / Philip BakerThe concept of dependence in the definition of a permanent establishment / Jean Pierre Le GallContract conclusion and agency permanent establishments : here, there, and everywhere? / Carol A. DunahooThe application of the OECD permanent establishment concept to electronic commerce / Daniel LuthiNew sources of tax revenue for transit countries : can a (rail) road qualify as a permanent establishment? / Kees van RaadDefining the term "business" for purposes of tax treaties / Brian J. ArnoldDivergence of third party pricing from arm's length results / Peter H. BlessingBeneficial ownership in tax treaties : judicial interpretation and the case for clarity / Jinyan LiJapan's foreign subsidiaries' dividends exclusion / Toshio MiyatakeExit taxes on substantial shareholdings and pension claims: the Dutch Supreme Court's interpretation of arts. 13, 15 and 18 of the OECD Model / Luc De Broe, Katrien WilloqueTax treaty override : Swedish developments / Bertil WimanDoes Art. 20 of the OECD Model Convention really fit into tax treaties? / Michael LangExemption and tax credit in German tax treaties : policy and reality / Jurgen LudickeRecent treaty developments in the arbitration of international tax disputes / Hugh J. AultThe |