Roy Rohatgi on International Taxation – Volume 1 | Principles

This is a unique book as it provides an in-depth treatment of the key topics in international tax, building up from a detailed explanation of the basic concepts to a solid analysis of the complex transactional issues.

With the book, the reader gets a thoroughly researched handbook explaining the key principles of international taxation, buttressed with real-world practice and written with practical application in mind.

This book examines international taxation through the prism of domestic law, explaining the conflict of laws that give rise to issues seeking resolution in the international arena. It also introduces the reader to the world of tax treaties, crucially focusing on income and capital tax treaties and the main treaties that concern the administration and collection of taxes in the international sphere.

In analysing the income and capital tax treaties, this book takes the OECD Model Convention as the starting point. It enriches the discussion with examples from real-life treaties and contrasts provisions from other Model treaties.

The Present Publication is one of the first authoritative works to include an analysis of the provisions of the updated OECD Model Convention (2017) and UN Model Convention (2017). The Present Publication is the latest edition, with the following contents:

• Introduction
• How Double Taxation Arises – The Role of Domestic Tax Systems
• Double Taxation Relief
• Tax Treaties and Their Role in International Taxation
• Model Conventions
• Multilateral Tax Agreements
• Treaties on Administrative Assistance
• Structure of Tax Treaties
• Scope of Tax Treaties – Persons Covered, Taxes Covered
• Residence
• Active Income of Companies
• Active Income of Individuals
• Passive Income
• Taxation of Income from Immovable Property
• Capital Gains
• Other Distributive Rules
• Methods for Elimination of Double Taxation
• Entitlement to Treaty Benefits
• Prohibition of Discrimination
• Administrative Provisions
• The Vienna Convention on the Law of Treaties
• Role of the OECD Commentaries
• Role of the OECD Multilateral Instrument
• Interaction between Domestic Law and Tax Treaties
• Lifecycle of Tax Treaties
• Tax Treaties and Dispute Resolution