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Anti-Abuse Rules and Tax Treaties

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Anti-Abuse Rules and Tax Treaties

作者： Georg Kofler
出版商： Kluwer Law International
ISBN: 9789403526584
出版时间 May 2024
规格： Hardback
适应领域： International ? 免责申明：
Countri(es) stated herein are used as reference only

List Price: ￥1,149.50

￥1,115.02 Save ￥34.49 (3%)

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About this book:

Anti-Abuse Rules and Tax Treaties is a book delving deep into current issues concerning the relations of various anti-abuse rules to each other and their impact on the application of tax treaties. As the struggle to combat tax abuse and tax avoidance gains momentum, ways of making a tax jurisdiction ‘manipulation-proof’ continue to proliferate, from new or revised provisions in model tax treaties to a dramatic increase in the number and variety of anti-abuse and anti-avoidance rules at all levels of government. These measures interact with national tax systems, general anti-abuse clauses and tax treaties, inevitably resulting in conflicts and other legal difficulties that deserve intensive scrutiny.

What’s in this book:

The following topics have been included:
- domestic general anti-avoidance rules (GAARs);
- domestic specific anti-avoidance rules (SAARs) (including controlled foreign company rules);
- minimum holding periods;
- indirect transfers of immovable property, shares, and rights;
- limitation on benefits;
- residence criteria in tax treaties;
- tax treatment of sportspersons and entertainers;
- the principal purpose test of Article 29 (9) OECD Model (2017); and
- influence of European Union Law on tax treaty abuse.
The chapters are revised and expanded versions of papers presented at the 30th Viennese Symposium on International Tax Law held on 12 June 2023 at Vienna University of Economics and Business. Each author thoroughly analyses a specific topic, drawing on the most recent scientific research.

How this will help you:

This one-of-a-kind book offers a wide-ranging, detailed, and pragmatic analysis of how the full range of anti-abuse rules interacts with tax treaties. It will be highly appreciated by practitioners and law firms active in tax planning, tax consultants, academics and researchers in international tax law and counsel for companies involved in international business.
List of Editors

List of Contributors

Preface

CHAPTER 1

Domestic GAARs and Their Impact on Tax Treaties

Alexander Rust & Valentina Emanuele

CHAPTER 2

Impact of Domestic SAARs on Tax Treaties

Ruth Mirembe & Claus Staringer

CHAPTER 3

Anti-Abuse Rules and Tax Treaties: Dual Resident Entities

Daniel W. Blum & Franz Wallig

CHAPTER 4

Minimum Holding Periods (Articles 10(2) and 13(4) OECD MC)

Josef Schuch & Iris Tschatsch

CHAPTER 5

Indirect Transfers of Immovable Property, Shares, and Rights: (Article 13(4) OECD Model and Article 13(5)-(7) UN Model)

Georg Kofler & Thomas Frenkenberger

CHAPTER 6

Sportspersons and Entertainers (Article 17, Paragraph 2 OECD MC)

Michael Hubmann

CHAPTER 7

Limitation on Benefits (Article 29 Paragraphs 1-7 OECD MC)

Pasquale Pistone & Severin Schragl

CHAPTER 8

Third-Country Permanent Establishments (Article 29 Paragraph 8 OECD MC)

Kristof Boel & Rita Szudoczky

CHAPTER 9

The Principal Purpose Test of Article 29(9) OECD Model (2017)

Michael Lang & Oleksandr Nesterov-Surmenko

CHAPTER 10

Harmful Tax Competition and Special Tax Regimes and Tax Treaties (Article 1 Paragraphs 85 Et Seq. OECD Model Commentary)

Rita Szudoczky & Ruth Wamuyu

CHAPTER 11

The Influence of European Union Law on Tax Treaty Abuse

Valentin Bendlinger

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