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Vol 21 No 11 Nov/Dec 2016

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International Tax Planning and Prevention of Abuse


ISBN13: 9789087220358
Published: August 2008
Publisher: IBFD Publications BV
Country of Publication: The Netherlands
Format: Hardback
Price: £168.00



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A Study under Domestic Tax Law, Tax Treaties and EC Law in relation to Conduit and Base Companies

This study considers how tax authorities attempt to strike down international tax avoidance structures in particular those involving the use of conduit and base companies set up by third country residents for purposes of “treaty shopping” and “EC-Directive shopping”.

The book essentially focuses on the interaction between provisions and judicially developed doctrines of domestic tax law preventing international tax avoidance, on the one hand, and norms of international law, in particular tax treaties and rules of Community law, on the other hand.

This book also considers the treaty based anti-avoidance measures such as beneficial ownership - requirement and limitation on benefits - provisions. This part of the study is truly comparative, analyzing the case law of Australia, Austria, Belgium, Canada, the Czech Republic, Finland, France, Germany, India, Switzerland, the United Kingdom and the United States.

Subjects:
Taxation
Contents:
Part One: The use of Conduit & Base Companies in International Tax Planning.
Part Two: Prevention of Abuse under Belgian Domestic Law.
Part Three: Conduit & Base Companies Prevention of Abuse under Belgian Tax Treaties.
Part Four: Conduit & Base Companies Prevention of Abuse under Community Law. ;