Interpretation of Double Taxation Agreement (in Thai)
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Abstract
Double Taxation Agreement is an international treaty where tax authorities of two countries mutually agreed to eliminate the double taxation that may arise. For most countries, the OECD and UN Model are the basic models that are widely accepted. However, noted that both models have no legal binding for countries. Tax authorities may negotiate any article differ from Models as they agree to each other. Moreover, there are many languages for the said agreement. Hence, when a dispute arises, the question is how should one interpret the Double Taxation Agreement.?
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References
Baker, P. (1994) Double taxation conventions and international tax law, Kluwer: Sweet & Maxwell.
Lenz, R. (1960) The general reporter in the international fiscal association’s 1960 report on the interpretation of double taxation conventions, Basel: Verlag für Recht and Gesellschaft.
Vogel, K. (1986) Double tax treaties and their interpretation, Berkeley Journal of International Law, vol. 4, pp. 1-85.