Double Taxation and the League of Nations

The first comprehensive historical study of the Model Tax Treaties developed by the League of Nations in 1928.

Sunita Jogarajan (Author)

9781108421447, Cambridge University Press

Hardback, published 10 May 2018

352 pages, 5 tables
23.5 x 15.7 x 2 cm, 0.7 kg

'This book gives a vivid picture of the negotiations that will be of interest to those having a wider interest in international taxation. It should be compulsory reading for those developing policy in this field. It is, unusually, a tax book that will never become out of date.' John Avery Jones, British Tax Review

Modern-day tax treaties have their foundations in one of the three Model Tax Treaties developed by the League of Nations in 1928. Using previously unexplored archival material, Sunita Jogarajan provides the first in-depth examination of the development of the League's Models. This new research provides insights into questions such as the importance of double taxation versus tax evasion; the preference for source-taxation versus 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 key individuals involved. A better understanding of the development of the original models will inform and help guide interpretation and reform of modern-day tax treaties. Additionally, this book will be of interest to scholars of international relations and the development of law at international organisations.

Preface
List of abbreviations
1. Introduction
2. Background
3. Personality, politics and principles: the drafting of the 1925 Resolutions on Double Taxation
4. The ICC and the development of the 1928 Models
5. Turning resolutions into treaties – the drafting of the first Model Convention on Double Taxation
6. The 'great powers' and the development of the 1928 Models
7. One beget three – the drafting of the 1928 Model Tax Treaties on Double Income Taxation
8. Lessons from history – where to from here?
Appendix 1. Timeline/cast of characters
Appendix 2. 1925 Report Final Resolutions
Appendix 3. 1921 ICC Resolutions
Appendix 4. 1922 ICC Resolutions
Appendix 5. 1923 ICC Resolutions
Appendix 6. 1924 ICC Resolutions
Appendix 7. 1925 ICC Resolutions
Appendix 8. 1927 ICC Resolutions
Appendix 9. 1927 Draft Model Convention
Appendix 10. 1925 UK Finance Act
Appendix 11. Thompson Art 10 Proposal
Appendix 12. USSR Art 5 Proposal
Appendix 13. USSR Art 10 and 11 Proposals
Appendix 14. Dorn and Borduge Draft Convention
Appendix 15. Thompson Draft Convention
Appendix 16. Adams Draft Convention
Appendix 17. Draft Convention IA
Appendix 18. Draft Convention IB
Appendix 19. Draft Convention IB Commentary
Appendix 20. Draft Convention IC
Appendix 21. Draft Convention IC Commentary
Bibliography
Index.

Subject Areas: Legal history [LAZ], Law [L], Taxation [KFFD1]