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Vol 22 No 2 Feb/March 2017

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Spencer Bower: Reliance-Based Estoppel

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The Improper Use of Tax Treaties

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ISBN13: 9789041107374
ISBN: 9041107371
Published: June 1998
Publisher: Kluwer Law International
Format: Hardback
Price: £165.00

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This reference work presents a detailed and comprehensive study of the improper use of tax treaties. The author provides a brief overview of both the occurrence and avoidance of double taxation and analyzes the history, purpose and structure of tax treaties, with particular attention to the relation between the treaty subject and treaty object, and the concept of beneficial ownership. The concept of the improper use of tax treaties is explored, specifically in the context of the abuse of rights doctrine, the purpose of tax treaties, and the expectations and policy objectives of contracting states. Finally, the book deals with the phenomenon of treaty shopping, other perceived improper uses of tax treaties, and the efforts to combat this. The latter are categorized in interpretation and application of substance over form principles, and domestic legislation and treaty provisions, in particular limitation on benefit provisions.

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Part 1 Double Taxation: Occurrence of double taxation. Rationale for the avoidance of double taxation. Avoidance of double taxation.
Part 2 Tax treaties: History and purpose. Structure. Part III Improper Use of Tax Treaties: The concept of improper use of tax treaties. Treaty shopping and other perceived improper use of tax treaties. Part IV Efforts to Combat Improper Use of Tax Treaties: Interpretation - application of substance over form principles. Provisions in or based on domestic legislation. Treaty provisions. Part V Conclusion and Recommendations.