Practical Issues in the Application of Double Tax Conventions:Problemes Pratiques D'Application des Conventions Contre la Double Imposition

The practical aspects of applying double tax conventions (DTCs) have increased in importance for tax authorities and tax payers, as DTCs grow in both numbers and complexity. Although they are normally matters of internal law, receiving limited international attention, their importance is becoming more and more substantial. This book surveys issues reported from member states, looking for best practices -- and noting problems -- that range from self-authorized claims or ready advance rulings to complex clearance procedures, or substantial uncertainties for topics such as residence claims and withholding taxes.