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IFA: How Domestic Anti-Avoidance Rules Affect Double Taxation Conventions
How Domestic Anti-Avoidance Rules Affect Double Taxation Conventions
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ISBN-13:
9789041186935
Veröffentl:
2016
Einband:
PDF
Seiten:
62
Autor:
International Fiscal Association
Serie:
IFA Congress Series Set
eBook Typ:
PDF
eBook Format:
PDF
Kopierschutz:
Adobe DRM [Hard-DRM]
Sprache:
Englisch
Beschreibung:
The question of whether there are internationally recognized anti-avoidance rules that are applied to tax treaties involves two subsidiary questions: (1) Whether international law recognizes the concept of abuse of rights, fraus legis (2) Whether this concept of abuse of rights, fraus legis, the business purpose test, etc., can be applied to tax treaties.The book then turns to the question of whether provisions included in the tax code that are expressly designed to re-characterize or deal with transactions that are considered to result in unacceptable avoidance of tax under the code can be extended and applied where there is an unacceptable avoidance of tax by virtue of the application of a tax treaty provision.
The question of whether there are internationally recognized anti-avoidance rules that are applied to tax treaties involves two subsidiary questions: (1) Whether international law recognizes the concept of abuse of rights, fraus legis (2) Whether this concept of abuse of rights, fraus legis, the business purpose test, etc., can be applied to tax treaties.The book then turns to the question of whether provisions included in the tax code that are expressly designed to re-characterize or deal with transactions that are considered to result in unacceptable avoidance of tax under the code can be extended and applied where there is an unacceptable avoidance of tax by virtue of the application of a tax treaty provision.