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Tax Treaties Analysis

Overseen by Bloomberg BNA’s esteemed board of international tax practitioners, Tax Treaties Analysis provides expert guidance of key tax treaties between the top trading countries in a quick-search, user-friendly format.

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Receive expert guidance and detailed analysis of key tax treaties, including at-a-glance summaries of the provisions, written by the most respected authorities in international tax.

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WHAT’S AVAILABLE

Primary Sources
Support your research with the full text of over 2,700 treaties, plus summaries of key International tax treaties — including OECD, US and UN Model Treaties — and their amending documents and Glossary of Terms. Documents available in native languages plus English translations.

TOPICS COVERED

Expert Analysis Topics 
  • Administrative Assistance 
  • Associated Enterprises — Transfer Pricing 
  • Business Profits — Branches, etc. 
  • Capital 
  • Capital Gains, Dividends and Royalties 
  • Elimination of Double Taxation 
  • Exchange of Information 
  • Income from Immovable Property 
  • Independent Personal Services 
  • Interest
  • Limitation of Benefits
  • Mutual Agreement
  • Nondiscrimination
  • Pensions
  • Permanent Establishment
  • Residence, including Tie-Breaker Rules
  • Scope, Type of Treaty, and Entry into Force
  • Students and Trainees
  • Taxes Covered
  • Teachers and Researchers
  • Treatment of Partnerships and Fiscally-Transparent Enterprises

COUNTRIES COVERED

  • Australia
  • Austria
  • Belgium
  • Brazil
  • Canada
  • China (PRC)
  • Czech Republic
  • Denmark
  • France
  • Germany
  • Hungary
  • India
  • Italy
  • Japan
  • Mauritius
  • Netherlands
  • Norway
  • Poland
  • Portugal
  • Russia
  • Singapore
  • Spain
  • Sweden
  • Switzerland
  • Thailand
  • United Kingdom
  • United States

 


    AUTHORS

    Thierry Boitelle

    Thierry Boitelle, a partner in Bonnard Lawson’s tax practice, specialises in national and international tax, finance, intellectual property and mergers & acquisitions. Additionally, Thierry is a member of the International Fiscal Association (IFA), the American Bar Association (ABA), Dutch Association of Tax Advisers (NOB), Dutch Association of Tax Science and the Dutch Group of Liberal International (LIGN). Thierry received a master’s degree in tax law from Leyden University in 1997 and a bachelor’s degree in Dutch civil law in 1991. He is fluent in Dutch, English, French and German.

     
    Michael Dirkis

    Dr Michael Dirkis is Professor of Taxation Law at University of Sydney and a noted researcher, having authored and co-authored over 550 publications and papers. From May 1999 until October 2009 he was, as Senior Tax Counsel for the Taxation Institute of Australia, in the forefront of the all major tax reform and taxation administration reforms through participation in key Australian governmental consultative forums conducted by the Treasury, Australian Taxation Office, the Board of Taxation, the Inspector General of Taxation and the Australian National Audit Office and appearing before numerous Parliamentary committees. He also engaged with international tax organizations such as the Irish Taxation Institute, Japan Federation of Certified Public Tax Accountant’s Association, the Japan Tax Research Institute, and the Asia-Oceania Tax Consultants’ Association, and with foreign revenue authorities through the Study Group on Asian Tax Administration and Research (SGATAR), the United States’ Government Accountability Office (GAO), New Zealand Inland Revenue Department, and HM Revenue & Customs.

     
    Ingmar Doerr

    Dr. Ingmar Dörr is a senior associate in Lovells’ International Tax Practice, based in Munich. He is admitted to work as an attorney-at-law and as a certified tax advisor in Germany. Main focus of his activity lies on the national and international tax law and the consultation of German and international clients in M&A/Private Equity and financing Transactions as well as the development and conversion of tax models. He is a graduate of University of Munich and wrote his doctoral thesis on the subject of European company taxation at the Max Planck Institute Munich. Ingmar is an author of numerous professional publications and a member of the International Fiscal Association.  

     
    Dorine Fraai

    Dorine Fraai is a senior tax manager for Horlings in Amsterdam, the Netherlands. Dorine works primarily in international tax law and has a diverse practice, focusing on international structures and foreign companies investing in the Netherlands and Dutch companies investing in different jurisdictions. She has more than 12 years of experience in international tax firms and has worked for various tax law firms. Dorine publishes articles on a regular basis for BNAI’s Tax Planning International Review regarding various issues, such as the Dutch co-operative in international holding structures. Additionally, she coordinates an international tax publication for Nexia International, which is a worldwide network of independent auditors, business advisors and tax consultants. On occasion, Dorine organizes and speaks at a number of tax conferences on Dutch tax issues for an international audience.  

     
    Akil Hirani

    Akil Hirani is the Head of Transactional Practice and Managing Partner of Majmudar & Co., International Lawyers in India (www.majmudarindia.com). Akil’s particular experience includes M&A, private equity, securities and corporate finance, tax, and investment structuring work. He represents Citigroup, Hitachi Metals and many other international companies and banks in India. Akil has been practicing since 1992. He is qualified to practice law in India, California, and England & Wales, although he is currently on inactive status in the latter two jurisdictions. His work experience includes a clerkship at the State Superior Court of Santa Clara County in San José, California, in 1995, and a stint at the London firm of Lawrence Jones (now known as TLT) in 1996. He has written extensively and spoken on M&A structures, capital raising, issues affecting hedge funds and FIIs, India investment strategies, and related subjects at many international forums, including at seminars held by Terrapin in India and Hong Kong, PLI and ATLAS Legal in the US, and the International Bar Association (IBA).  

     
    Benjamin Homo

    Benjamin Homo is a Partner in the Paris office of Mayer Brown. He advises a large number of French and foreign private equity clients and corporate groups on their acquisitions, financing, and real estate transactions. He has developed a strong experience of all aspects of multi-country transactions, from tax due diligence to structuring work, including financing issues, and has been involved in most of the larger deals (above €1 billion) carried out on the French market over the past years. In his work on such transactions, Benjamin analyzes, develops, and manages complex financial models which allow him to translate multi-jurisdiction tax advice into cash flow simulations, helping his clients understand and analyze with their own tools and language the consequences of cross-border taxes on the economics of the transaction. Benjamin also advises French private equity clients with respect to their own fund structure, and he has provided structuring advice for the creation of several real estate or private equity funds. In addition, Benjamin assists corporate clients in their day-to-day tax management (tax audit/litigation, reporting tools) and in the reduction of their global effective tax rate (French and international tax planning, transfer pricing, and similar concerns). Before he joined Mayer Brown in 2004, Benjamin was a member of a major financial consulting firm’s Paris office. He is fluent in both French and English.  

     
    Justin Liebenberg

    Justin Liebenberg is the Director of International Tax Services at Ernst & Young, South Africa. Justin specializes in corporate tax law advising on domestic and international issues. Justin was previously head of tax at Grant Thornton in Johannesburg and assistant head of tax at Cliffe Dekker Hofmeyr, one of the largest business law firms in South Africa. He has a combination of legal, tax and accounting qualifications and is often published in the financial press in South Africa.

     
    Johann Muller

    Johann Muller is an international tax manager at the A.P. Møller Mærsk Group in Denmark. Johann is a member of the tax department of the A.P. Moller Maersk group, where he is heading its tax risk management team. He has been working at A.P. Moller Maersk A/S since September 2006. Prior to that, he ran his own practice after having worked in the international tax practice for various Dutch law firms in Holland, the UK and the US. Johann is the author of numerous articles on international taxation and EU law on direct taxation. He is a member of the International Fiscal Association, the Tax Executives Institute (chairperson for the European Direct Tax Committee) and the European American Tax Institute.

     
    Mario Petriccione

    Mario Petriccione is a Director of International Corporate Tax at KPMG LLP in London. BA (Economics, Cambridge University), ACA, ATII. Mario was brought up in Italy and went to Cambridge University as an overseas student. He graduated in 1979 with a BA (Economics, Cambridge University), ACA, ATII. Since then he has been based in London. He specializes in advising large companies on cross-border acquisitions and reorganizations. His clients include some of the larger UK and foreign multi-nationals, with a special focus on emerging markets. Mario is the author of numerous articles on tax in China, India and Africa, which have appeared in a wide range of tax publications. Mario is a visiting lecturer and examiner on the International Tax Law LLM course at Leiden University, the Netherlands. He also teaches at the Brazilian Tax Law Institute in São Paulo, and at Said Business School (Oxford University).

     
    Astrid Pieron

    Astrid Pieron is a Partner in the Brussels office of Mayer Brown. She has more than 25 years of tax experience, which includes more than 20 years of focus on international taxation. Her practice covers the fiscal aspects of financial functions within multinational groups, tax optimization of mergers and acquisitions, structuring of financial products and investment funds, and general assistance to private equity deals. Astrid has had a primary geographic emphasis on Brussels and Luxembourg throughout her career, and together with Mayer Brown’s Paris office (which won the 2006 Private Equity Award) she is advising on most of the significant private equity transactions that directly or indirectly are connected to the Benelux countries. In addition to her transactional work, Astrid has substantial background in tax controversy matters, including assistance with tax litigation and negotiation of rulings with the tax authorities in Belgium and Luxembourg. Her experience in transfer pricing controversy includes examination, appeals and advance pricing agreements. She also counsels on the transactional aspects of transfer pricing, such as structuring European transfer pricing policy for US manufacturing groups operating in Europe. Astrid’s related work involves advising on the conversion to commissionaire structures as well as on the fiscal optimization of financial vehicles within multinational enterprises (such as captive insurance companies, treasury centers, and investment funds). Before joining and subsequently becoming a partner in Mayer Brown’s Brussels office in 2007, Astrid practiced in Brussels and Luxembourg with two of the world’s leading tax and accounting firms: Deloitte (2002 to 2006) and Arthur Andersen (1981 to 2002). Reflecting her multinational practice, she is fluent in French, Dutch, and English. 

     
    Arne Riis

    Arne Riis is a partner in the tax department of Copenhagen based law firm Bech-Bruun. Bech-Bruun is a leading Danish law firm advising on all aspects of corporate law and the Bech-Bruun tax department is ranking top tier in Chambers, Legal 500 and Who's who Legal. Further, Bech-Bruun is a 3-time winner of the International Tax Review Danish international tax law firm of the year, most recently in 2008.Arne Riis has been advising Danish and foreign banks, venture funds, real estate funds as well as blue chip and larger corporations on all aspects of Danish and international corporate tax law since 2000, focusing in particular on tax in relation to Danish and international structured finance and derivatives structures as well as M&A taxation. He is the author of several tax articles published in Denmark and abroad, including with the BNAI's Tax Planning International Review, and a frequent speaker on tax seminars in Denmark and abroad. Further, he is a regular contributor to the Danish practitioners guide on international tax law, “Dobbeltbeskatning”. Arne Riis is a member of the D anish Bar Association. Further, he is a member of International Fiscal Association (IFA), Dansk Skattevidenskabelig Forening (Danish Tax Science Association), AIJA Tax Law Commission and numerous other tax associations.

     
    James Ross

    James Ross is a partner in the law firm of McDermott Will & Emery UK LLP, based in its London office. His practice focuses on a broad range of international and UK domestic corporate/commercial tax issues, including corporate restructuring, transfer pricing and thin capitalization, double tax treaty issues, corporate and structured finance projects, mergers and acquisitions and management buyouts. He has particular experience in advising US groups in the structuring of UK and European inbound investments, group restructurings and providing advice on technical issues in the context of revenue investigations and statutory audits. His experience also includes advising on employment tax issues, the taxation of the trading of energy and energy derivatives and tax aspects of private equity transactions.

     
    Sakura Shiga

    Sakura Shiga is a Partner at Shiga & Associates in Japan. Educated at the University of Tokyo, Sakura was admitted in 2005 to the Dai-Ichi Tokyo Bar Association and is admitted to work as an attorney-at-law and as a certified tax advisor in Japan. In addition to working for Japan’s Ministry of Finance, Sakura acted as a counsellor for the Embassy of Japan to the United Kingdom, Ministry of Foreign Affairs and is currently a member of the Executive Committee of the International Fiscal Association (representing Japan).

     
    Paolo Tognolo

    Paolo Tognolo is a tax partner at Studio Tributario Tognolo in Milan. He regularly provides tax advice to several Italian multinational groups and helps a trustful support to foreign multinational groups on Italian and international tax matters. He also performs the statutory auditor’s legal control activities for many relevant Italian legal entities. Paolo is widely experienced in streamlining projects and the reorganization of European groups; international tax treaties and double taxation aspects, permanent establishment, transfer pricing, e-commerce and M&A. Paolo attained a degree in economics from Bocconi University and is a member of the State Tax Consultants Association and the State Chartered Accountant Association. Paolo is fluent in Italian, French and English. He regularly lectures at external courses, seminars and workshops for several domestic and international organizations on domestic and international tax matters. 

     
    Edwin Vanderbruggen

    Edwin Vanderbruggen is the Senior Regional Tax Counsel and head of the Indochina Tax Practice. He holds a Bachelor in Law (Antwerp) and a Master in Tax Law (Brussels). He advises multinational enterprises and international organizations in the field of taxation and specializes in the Indochina region and international tax planning. Besides extensive tax consulting work for multinational enterprises he has regularly trained and assisted tax department officials in various countries, designed policy and drafted tax laws and regulations and has supplied expert testimony to tax courts. He has also trained and advised governmental agencies on international trade/investment law and arbitration. He has published more than forty scientific articles in international legal journals and five books on international law, taxation and investment law issues, some of which won scientific awards. He speaks Dutch, German, English, French and Thai. 

     
    Dariusz Wasylkowski

    Dariusz Wasylkowski an adwokat, a tax adviser and a senior partner in charge of the Tax Practice Group at Wardyński & Partners. He advises on Polish as well as international tax law. He represents clients in tax litigation as well as in civil and criminal litigation relating to tax matters, and provides services to both foreign and domestic clients active in a broad range of sectors from manufacturing, distribution and retail to financial services and private equity. His tax advisory experience includes providing support to clients in corporate tax planning, structuring of inbound investment, transfer pricing and M&A. Contentious tax experience includes advising clients during audits and representing them in administrative proceedings and litigation at all levels of judicial review of tax cases. He has also represented clients in litigation related to customs, regulated prices regimes and similar administrative matters, and also in criminal and civil litigation related to tax and similar matters. Dariusz Wasylkowski is a member of the Warsaw Bar and of the Polish Chamber of Tax Advisers (Disciplinary Tribunal Judge at the National Chamber of Tax Advisers). He is a member of Advisory Board of the European Forum of the International Bar Association (IBA) and a member of the IBA Tax Section, and also of the International Fiscal Association (Chairman of the Polish Branch). He is an associate member of the Section of International Law and the Section of Taxation of the American Bar Association. 

     
    Nick Webb

    Nick Webb is BNA Tax & Accounting's Managing Editor, International Tax, and has editorial responsibility for BNA's publications covering the tax systems of foreign countries as well as international tax treaties. Nick edits BNA's Country Portfolios (Business Operations Abroad Portfolios Series), International Forum, and International Journal. Prior to joining BNA, Nick spent five years with IK Inland Revenue (now HM Revenue and Customs) and seven years with IBFD Head, Asia-Pacific Group. He has done freelance work for both KPMG and Deloitte.Nick holds a B.A. from Reading University, England, and Full Tax Training, UK Inland Revenue.

     
    Jim Wilson

    Jim Wilson is a partner in Gowlings’ Ottawa office, practicing in conjunction with the Firm’s National Tax Practice Group. His practice focuses on helping organizations optimize their global tax position and reduce exposure to unfavorable audit assessments through proper tax planning and implementation strategies. Jim’s tax experience involves the administration of domestic corporate and international tax with the Canada Revenue Agency (CRA) for 32 years. Jim held various positions with CRA’s Income Tax Rulings Directorate (“Rulings”), the Canadian Competent Authority Division (“Competent Authority”), the Training and Learning Directorate and the Legislative Policy Division. During Jim’s tenure as both a senior officer and a senior manager of the International Section in Rulings, he participated in hundreds of Advanced Income Tax Rulings and Technical Interpretations on a wide range of international technical issues. As a senior manager with Competent Authority for six years, Jim has been successful in resolving a number of controversial international double tax cases through successful negotiations with tax authorities in a number of countries around the world. Even though Jim developed an impressive specialty with tax treaties during his last 20 years with the CRA, he possesses a vast array of experience with issues such as residence and dual resident cases, permanent establishments, benefit conferrals, tower structures, e-commerce income characterization, hybrid entities, foreign entity classifications, foreign tax credit system, and Canada’s withholding tax system. From his tenure as a senior manager with Competent Authority Services, Jim’s experience expanded to a multitude of technical and policy issues pertaining to the CRA’s MAP and APA programs. This would include expertise on ACAPs, interest relief, secondary adjustments, notional expenses, imputed interest, Article XIII(8) agreements, and S-Corp agreements.


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