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Current tax treaty issues related to interpretation paper


Although not much has happened on the surface since the US protocol and UK treaty were signed, Australia has actively been renegotiating treaties. In addition the ATO and the OECD produce a stream of treaty related material and the legislature tweaks domestic law to fit with treaties better (eg for employee share options). Issues covered in this paper include:

  • what have been the flow on impacts of the US / UK Treaty protocols?
  • what are the current trends for upcoming treaty negotiations?
  • recent OECD developments and recent Australian rulings and treaty related legislation.

Author profile

Prof Richard Vann CTA
Prof Richard Vann, CTA, is Challis Professor of Law at the University of Sydney and a Consultant at Greenwoods & Herbert Smith Freehills. He has also taught at NYU Law School, Harvard Law School and the University of London. He has held many government consultancies in Australia, including the Review of Business Taxation (1998 - 1999), the Review of International Taxation (2002 - 2003) and the Australian Taxation Office Public Rulings Panels on international and indirect taxation (1995-2007). Most recently, he has been involved in various Board of Taxation work on managed investment trusts and collective investment vehicles, the attribution of profits to permanent establishments and as a member of Treasury’s BEPS Advisory Group. Richard is the Editor-in-Chief of the IBFD Global Tax Treaties Commentaries now being progressively published. - Current at 14 July 2017
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This was presented at International Tax Masterclass 2005 .

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