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1156 results in Taxation Law

Page 26 of 58

  • 5 - Turning Resolutions into Treaties

  • Sunita Jogarajan, University of Melbourne
  • Book:
    Double Taxation and the League of Nations
    Published online:
    28 April 2018
    Print publication:
    10 May 2018, pp 98-166

  • Summary

    Chapter 5 examines the second time period in the League's work on double taxation, 1926–1927, and details the drafting of the 1927 Report. The 1927 Report included a first draft of a model double tax agreement on double taxation. The 1927 Report was drafted by the original seven Experts who drafted the 1925 Report, and also included Experts from an additional six countries. Chapter 5 shows that the new Experts felt bound by the resolutions in the 1925 Report, as they were not privy to the earlier discussions and respected the fact that their colleagues had reached their conclusions following extensive deliberations. Much of the 1926 and 1927 sessions rehashed the earlier discussions, and the text of the model treaty was developed in a short time frame.

  • 7 - One Beget Three

  • Sunita Jogarajan, University of Melbourne
  • Book:
    Double Taxation and the League of Nations
    Published online:
    28 April 2018
    Print publication:
    10 May 2018, pp 182-242

  • Summary

    Chapter 7 discusses the drafting of the three model treaties on double income taxation published by the League in 1928. The 1928 Models were the result of a single conference of representatives from 27 countries held from 22 to 31 October 1928. From the outset, the delegates at the 1928 Meeting were tasked with achieving practical results in the form of useful model treaties, and were advised that the time for theoretical discussion had passed. The 1928 Meeting again rehashed many of the discussions that had taken place previously and was largely focused on finalising the 1927 model treaty, which distinguished between personal and impersonal taxes. It was only towards the end of the Meeting that the Experts turned their attention to the development of two alternative conventions which did not distinguish between the two types of taxes. The 1928 Meeting also finalised the commentary accompanying the 1928 Models. Due to the practical nature of their work, the 1928 Experts were largely wedded to the original resolutions in the 1925 Report.

  • 8 - Lessons from History

  • Sunita Jogarajan, University of Melbourne
  • Book:
    Double Taxation and the League of Nations
    Published online:
    28 April 2018
    Print publication:
    10 May 2018, pp 243-256

  • Summary

    Chapter 8 discusses the historical insights drawn from the detailed account of the drafting of the 1928 Models. There are many parallels between the discussions that took place almost a century ago and the discussions that have taken place in recent decades, and which continue today. This chapter provides insights into questions such as the importance of double taxation vs tax evasion; the preference for source-taxation vs residence-taxation; the influence of theory and practice on the League’s work; the development of bilateral rather than multilateral treaties; the influence of developing countries on the League’s work; the role of Commentary in interpreting model tax treaties; and the influential factors and individuals on the League’s work. This chapter also provides broader conclusions regarding legal process and development at the League of Nations.

  • 6 - The ‘Great Powers’ and the Development of the 1928 Models

  • Sunita Jogarajan, University of Melbourne
  • Book:
    Double Taxation and the League of Nations
    Published online:
    28 April 2018
    Print publication:
    10 May 2018, pp 167-181

  • Summary

    Chapter 6 explores the influence of the two ‘great powers’, Great Britain and the United States of America, on the development of the League's 1928 Models. It has been said that the United States of America significantly influenced the development of the 1928 Models, but that does not seem to be the case. Due to domestic politics, America was not involved in the League’s work on double taxation until 1927, and thus was limited in its influence given the continuous nature of the League’s work. In contrast, Britain exerted more influence as it was involved in the League’s work from the beginning, and was considered ‘a great economy’ that needed to agree to the proposals. Many compromises were made for the British position.

Page 26 of 58