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Vol 22 No 11 Nov/Dec 2017

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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



Despatched in 9 to 11 days.

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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Contents:
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.

Series: Series on International Taxation

Price on Application
Winning the Tax Wars: Tax Competition and Cooperation ISBN 9789041194602
To be published December 2017
Kluwer Law International
£98.00
BRICS and International Tax Law ISBN 9789041194350
To be published December 2017
Kluwer Law International
£122.00
Legal Interpretation of Tax Law 2nd ed ISBN 9789041184733
Published October 2017
Kluwer Law International
£123.00
General Anti - avoidance Rules for Major Developing Countries ISBN 9789041158390
Published October 2014
Kluwer Law International
£96.00
Proportionality and Fair Taxation ISBN 9789041158383
Published October 2014
Kluwer Law International
£104.00
Legal Interpretation of Tax Law ISBN 9789041149459
Published September 2014
Kluwer Law International
Out of print
Tax Reform in the 21st Century: A Volume in Memory of Richard Musgrave ISBN 9789041128294
Published July 2009
Kluwer Law International
£81.00
Interpretation Double Taxation Conventions: General Theory and Brazilian Perspective ISBN 9789041128225
Published February 2009
Kluwer Law International
£110.00
Sales Taxation ISBN 9789065443816
Published January 2002
Kluwer Law International
£138.00
Taxation of Foreign Direct Investment ISBN 9789041197412
Published August 1999
Kluwer Law International
£120.00
The Impact of State Sovereignty on Global Trade and International Taxation ISBN 9789041197030
Published May 1999
Kluwer Law International
£116.00
Multilateral Tax Treaties ISBN 9789041107046
Published June 1998
Kluwer Law International
£144.00
Taxing Corporate Profits in the EU ISBN 9789041107039
Published September 1997
Kluwer Law International
£181.00
Tax Treatment of Financial Instruments ISBN 9789065446664
Published June 1995
Kluwer Law International
£195.00
Issues in International Partnership ISBN 9789065445773
Published July 1993
Kluwer Law International
£151.00
Permanent Establishment: Erosion of a Tax Treaty Principle ISBN 9789065445940
Published October 1991
Kluwer Law International
£284.00
International Juridical Double Taxation of Income ISBN 9789065444264
Published September 1989
Kluwer Law International
£183.00
Nondiscrimination in International Tax Law ISBN 9789065442666
Published July 1988
Kluwer Law International
£177.00
Tax Co-ordination in the European Community
ISBN 9789065442727
Published March 1987
Kluwer Law International
£251.00
International Studies in Taxation
ISBN 9789041196927
Published December 0002
Kluwer Law International
£165.00
Towards Corporate Tax Harmonization in the European Community
Adolfo J. Martin JimenezAssociate Professorr of Tax Law, University of Cadiz Law School, Jerez de la Frontera, Spain
ISBN 9789041196903
Published December 0002
Kluwer Law International
£193.00
Tax Treaties and EC Law
ISBN 9789041106803
Published December 0002
Kluwer Law International
£192.00