Legal Considerations Arising from the Use of Memoranda of Understanding in Bilateral Tax Treaty Relations

G. Maisto (Ed.), Current Tax Treaty Issues: 50th Anniversary of the International Tax Group (2020, IBFD Amsterdam), 359-438.

75 Pages Posted: 12 Dec 2019 Last revised: 2 Dec 2020

Date Written: December 6, 2019

Abstract

Results of a study about the use of memoranda of understanding in bilateral tax treaty relations and assessment of the legal considerations arising under international law and national law, as evidenced in selected domestic court cases.

Keywords: international treaty law; international tax treaty law, memoranda of understanding

JEL Classification: K33, K34

Suggested Citation

Hattingh, Johann, Legal Considerations Arising from the Use of Memoranda of Understanding in Bilateral Tax Treaty Relations (December 6, 2019). G. Maisto (Ed.), Current Tax Treaty Issues: 50th Anniversary of the International Tax Group (2020, IBFD Amsterdam), 359-438., Available at SSRN: https://ssrn.com/abstract=3499511

Johann Hattingh (Contact Author)

University of Cape Town ( email )

Private Bag X3
Rondebosch
Cape Town, Western Cape 7701
South Africa

HOME PAGE: http://www.tax.uct.ac.za/aprof-johann-hattingh

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