IFA: Abusive Application of International Tax Agreements

Abusive Application of International Tax Agreements

By:

International Fiscal Association (Ifa)

Format:

Paperback / softback

Series:

IFA Congress Series Set

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Description

The main goal of this seminar is to clarify on the basis of case studies what is meant by the concept of abusive application of tax treaties and whether and to what extent the concept of abuse is a domestic one and/or one of treaty law. To the extent that the concept of abuse is a purely domestic one, the question arises how domestic anti-avoidance rules affect double taxation conventions and to what extent one contracting state, for the purpose of taxation, should be prepared to consider the other contracting state's notion of abuse. To the extent that the concept of abuse is one of treaty law, it has to be clarified whether such a concept is known in Treaty law as an unwritten rule or whether the treaties need to include an express provision. Another important question in this respect is whether abusive use of tax treaties by contracting states is possible, e.g. by denying the access to the treaty or by implementing exit charges in the national legislation. What is or can be the role of the OECD in this process and to what extent does EC law innuence the way abuse of tax treaties can be tackled?

Release date Australia

October 1st, 2001

Author

International Fiscal Association (Ifa)

Audiences

Postgraduate, Research & Scholarly
Professional & Vocational

Pages

Series

IFA Congress Series Set

Dimensions

155x230x7

ISBN-13

9789041116734

Product ID

3964769

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