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基本説明
Publication delayed (Originally scheduled in March 2003). Covers the purpose of treaties, background to the new convention, general discussion on treaty trends and OECD.
Full Description
This detailed commentary on the UK/US Double Tax Treaty covers the purpose of treaties, background to the convention, a general discussion on treaty trends and the OECD. The publication consists of a detailed analysis of each article, including: the text of the relevant article in full; an overview outlining the need for the article and its broad effect indicating any significant differences from the OECD or US model treaties; a discussion of the key terms highlighting any developments and differences since the old treaty and commenting on the interaction with other treaty articles; envisaged difficulties in application or contentious issues including areas that the treaty does not address or adequately provide for; reference to relevant commentaries from US or UK authorities; and a general explanation of any available planning opportunities using the article e.g. standard structures or treaty uses.
Contents
The publication will be structured as an article-by-article analysis. For each article there will be included: * the text of the relevant article in full * an overview outlining the need for the article and its broad effect and indicating any significant differences from the OECD or US model treaties and why these have been adopted * discussion of the key terms highlighting any developments and differences since the old treaty and commenting on the interaction with other treaty articles * envisaged difficulties in application or contentious issues including areas that the treaty does not address or adequately provide for, and reference to relevant commentaries from US or UK authorities; and * a general explanation of any available planning opportunities using the article e.g. standard structures or treaty uses
