Taxation of Human Capital and Employment aboard Ships: Identification of the “Economic Employer” in International Maritime Practice

Journal
International
Bulletin for International Taxation 2013 (Volume 67), No. 11
This article attempts to reconcile the rules of international tax law with the commercial practices (and contracts) as adopted in the international shipping industry, while, simultaneously, ascertaining the key to interpreting tax treaties, consistent with the context, so as to realize as great as possible a harmonized approach.