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Vol 23 No 3 March/April 2018

Book of the Month

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Scamell and Gasztowicz on Land Covenants

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Limitation on Benefits Clauses in Double Taxation Conventions 2nd ed

ISBN13: 9789041161352
Previous Edition ISBN: 9041123709
Published: September 2017
Publisher: Kluwer Law International
Country of Publication: The Netherlands
Format: Hardback
Price: £155.00

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Limitation on Benefits Clauses in Double Taxation Conventions analyses the legal framework and application of limitation on benefits clauses (LOB) in double taxation conventions (DTC), including detailed coverage of major recent developments such as the recent tax treaties concluded between the United States (US) and European Union (EU) Member States, the last version of the US Model Tax Convention (2016), the OECD/G20 project on Base Erosion and Profit Shifting, and relevant new rulings handed down by the European Court of Justice.

Upfront planning for international structures is crucial to ensure coverage under bilateral tax treaties. However, as treaty shopping – whereby a third-party national or a corporation sets up a shell company in order to minimize or eliminate income tax – can potentially be facilitated by taking advantage of DTC, companies must carefully scrutinize and comply with requirements found in the LOB clauses in tax treaties. This book studies the specific rules laid down in tax treaties against treaty shopping and, in particular, one type of rule, the LOB.

What’s in this book:

Among the subjects and topics covered are the following:-

  • definition of the concepts of person and residence provided in the OECD model;
  • concept of beneficial owner;
  • application of domestic anti-avoidance rules;
  • adoption of specific provisions to counter the phenomenon of treaty shopping;
  • determination of sufficient nexus with the state of residence or a real business purpose; and
  • possible consequences of the incompatibility of LOB clauses with EU law.
How this will help you:

This new edition will continue to provide tax attorneys, tax professionals, and government officials with the perspective needed for effective decision-making in this realm of international taxation. This book deals exclusively with a subject matter of real importance to international tax professionals and their clients. Academics and researchers in taxation will also appreciate the in-depth and up-to-date coverage of this important subject.

List of Abbreviations
Chapter 1 Taxation of Non-Residents and International Tax Planning Through Double Taxation Conventions
Chapter 2 The Subjective Scope of Double Taxation Conventions and Limitation on Benefits Clauses
Chapter 3 Legal Framework and Application of Limitation on Benefits Clauses
Chapter 4 Limitation on Benefits Clauses and European Union Law

Series: Eucotax Series on European Taxation

Investment Fund Taxation: Domestic Law, EU Law, and Double Taxation Treaties ISBN 9789041196699
Published May 2018
Kluwer Law International
Price on Application
National Legal Presumptions and European Tax Law ISBN 9789041166135
Published February 2018
Kluwer Law International
Double (Non-) Taxation and EU Law ISBN 9789041194107
Published November 2017
Kluwer Law International
EU Citizenship and Direct Taxation ISBN 9789041185846
Published October 2017
Kluwer Law International
Transfer Pricing in the US: A Practical Guide ISBN 9789041191960
Published September 2017
Kluwer Law International
The Impact of Tax Treaties and EU Law on Group Taxation Regimes ISBN 9789041169051
Published August 2016
Kluwer Law International
Corporate Tax Base in the Light of IAS/IFRS and EU Directive 2013/34: A Comparative Approach ISBN 9789041167453
Published July 2016
Kluwer Law International
Tax Treaty Override ISBN 9789041154064
Published April 2014
Kluwer Law International
Fixed Establishments in European VAT ISBN 9789041145543
Published August 2013
Kluwer Law International
CCCTB: Common Consolidated Corporate Tax Base - Selected Issues (EUCOTAX 35)
Edited by: Dennis Weber
ISBN 9789041138729
Published May 2012
Kluwer Law International
Intermediation of Insurance & Financial Services in European VAT ISBN 9789041137326
Published August 2011
Kluwer Law International
From Marks & Spencer to X Holding: The Future of Cross-Border Group Taxation ISBN 9789041133991
Published August 2011
Kluwer Law International
Fiscal Sovereignty of the Member States in an Internal Market: Past and Future ISBN 9789041134035
Published December 2010
Kluwer Law International
Europe-China Tax Treaties ISBN 9789041132161
Published June 2010
Kluwer Law International
Taxation of Ucits: Austria Germany the Netherlands and the Uk ISBN 9789041128393
Published October 2009
Kluwer Law International
Integration Approaches to Group Taxation in European Internal Market ISBN 9789041127792
Published October 2008
Kluwer Law International
Tax Compliance Costs for Companies in an Enlarged European Community ISBN 9789041126665
Published May 2008
Kluwer Law International
ECJ-Recent Developments in Direct Taxation ISBN 9789041125095
Published March 2006
Kluwer Law International
Limitation on Benefits Clauses in Double Taxation Conventions ISBN 9789041123701
Published December 2005
Kluwer Law International
Out of print
Tax Avoidance and EC Treaty Freedoms ISBN 9789041124029
Published December 2005
Kluwer Law International
WTO and Direct Taxation ISBN 9789041123718
Published May 2005
Kluwer Law International
Tax Competition and EU Law
Carlo PintoResearch Associate, Department of Law, University of Amsterdam, Netherlands
ISBN 9789041199133
Published May 2003
Kluwer Law International
Settlement of Disputes in Tax Treaty Law ISBN 9789041199041
Published September 2002
Kluwer Law International
Tax Treaty Interpretation
Edited by: Michael Lang
ISBN 9789041198570
Published June 2002
Kluwer Law International
The Impact of Community Law on Tax Treaties: Issues and Solutions ISBN 9789041198600
Published February 2002
Kluwer Law International
The Compatibility of Anti-abuse Provisions in Tax Treaties with EC Law
ISBN 9789041196781
Published January 1999
Kluwer Law International
The Principle of Equality in European Taxation
ISBN 9789041196934
Published December 0002
Kluwer Law International