Resumen del libro

Reseña: Inspired by a postgraduate course the authors have jointly taught at the University of Cambridge since 2001, Peter Harris and David Oliver use their divergent backgrounds (academia and tax practice) to build a conceptual framework that not only makes the tax treatment of complex commercial transactions understandable and accessible, but also challenges the current orthodoxy of international tax norms. Designed specifically for postgraduate students and junior practitioners, it challenges the reader to think about tax issues conceptually and holistically, while illustrating the structure with practical examples. Senior tax practitioners and academics will also find it useful as a means of refreshing their understanding of the basics and the conceptual framework will challenge them to think more deeply about tax issues.

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indice: Preface List of abbreviations Table of cases Table of statutes Table of treaties Introduction 1 1 Fundamentals and sources of international tax law 8 1.1 Tax fundamentals 8 1.2 Sources of international tax law and their interrelationship 14 1.2.1 Domestic law 14 1.2.2 Tax treaties 16 What are they and where did they come from? 16 How tax treaties take effect in domestic law 20 Can a treaty create or increase tax? 24 1.2.3 EU Law 25 FEU Treaty 25 Directives 26 1.2.4 Other sources 27 GATT and the WTO 27 European Convention on Human Rights 28 1.3 Approaches to interpretation of material 28 1.3.1 Domestic law 29 1.3.2 Treaty interpretation 30 Vienna Convention 31 OECD Commentaries 34 Which Commentary? 37 Dispute resolution 38 1.3.3 Jurisprudence of the ECJ 38 2 The jurisdiction to tax 43 2.1 Forms of economic allegiance 43

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