If you were the attorney for a suspect in a criminal case, when would you recommend plea bargaining? What circumstance would bring you to make that recommendation?
Discuss the pros and cons of plea bargaining.
dentical cases of double taxation. The first recommendation related to the double taxation issue was published in 1955 by the Organisation for European Economic Co-operation (i.e. the predecessor of OECD), by that time being already in force double tax conventions between several countries, as well one of the first model bilateral conventions, i.e. Model Conventions of Mexico (1943) and London (1946). However, neither of these Model Conventions were fully and unanimously accepted by countries. After the Second World War, when the economic interdependence and co-operation between the countries increased due the so known globalisation process, the OECD members showed increasingly of the importance of measures to be taken for preventing the international double taxation. In 1963 the Fiscal Committee presented the first Draft Convention, envisaging that it might be revised on a later stage. Further on, all the efforts of the Fiscal Committee of OECD and, after 1971, its successor the Committee of Fiscal Affairs, resulted in the publication of the Model Tax Convention and Commentaries, in 1977. Due to the extended influence of the Model Tax Convention far beyond the OECD member countries, the Committee decided that the revision process should be open also for input of non-member countries, international organisations or other interested parties. This led to publication of newly enacted Model Convention in 1992 – since then it was updated 10 times (i.e. in 1994, 1995, 1997, 2000, 2002, 2005, 2008, 2010, 2014 and 2017). The 2017 update included a large number of changes resulting from the OECD/G20 Base Erosion and Profit Shifting (“BEPS”). ¬ Role of OECD Model Convention and Commentaries The increased conclusion of Double Tax Conventions (“DTC”) led to necessity of continuously update the Model Tax Convention and Commentaries (“MTC”). Probably the main function of the MTC is linked to harmonisation function, by laying down unified set of allocation rules and determination of DTC’ scope. The MTC’s commentaries present interpretations where Vienna Convention on Law of Treaties (“VCLT”) lack to provide co>GET ANSWER