Double Taxation Agreements 2011
- PART I-COMMENTARY ON THE LAW OF TAXATION TREATIES
- CHAPTER 1: THE EVOLUTION OF DOUBLE TAXATION TREATIES AND THE OECD MODEL
- 1.1 Why do we have tax treaties?
- 1.2 Forms of double taxation
- 1.3 Forms of double taxation relief
- 1.4 Unilateral relief
- 1.5 The evolution of tax treaty networks
- 1.6 Basis on which taxation rights may be divided
- 1.7 Format and effect of double taxation treaties
- 1.8 Format and content of the OECD Model treaty
- 1.9 Negotiation of treaties
- CHAPTER 5: INTERNATIONAL AND IRISH LAW ON THE INTERPRETATION OF TREATIES
- 5.1 Schematic and teleological method of interpreting treaties
- 5.2 Language to be interpreted based on general rather than peculiarly local interpretations
- 5.3 Liberal interpretation of treaties
- 5.4 Reliance on material external to the treaty text
- 5.5 Article 3(2) of the OECD Model treaty
- 5.6 Static or dynamic / ambulatory approach to domestic law