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The Improper Use of Tax Treaties : With Particular Reference to the Netherlands and the United States :  With Particular Reference to the Netherlands and the United States - Stef Van Weeghel

The Improper Use of Tax Treaties : With Particular Reference to the Netherlands and the United States

With Particular Reference to the Netherlands and the United States

Hardcover

Published: March 1998
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In the modern international tax world, tax advisors may assist their clients in using tax treaties in a manner clearly contrary to the treaties intent. With the right guidance, investors can determine which treaties offer the most beneficial access to the company of the desired investment. Investors have been known to go so far as to quickly set up corporations in countries with no connection to themselves or to the target country, simply to take advantage of a particular treaty network. In response, governments have sought means to curb these and other 'improper' tax treaty practices.This reference work offers a detailed and comprehensive study of the improper use of tax treaties. The author's examination includes: a concise overview of both the occurrence and avoidance of double taxation; an analysis of 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; an exploration of the concept of the improper use of tax treaties specifically in the context of the abuse of rights doctrine, the purpose of tax treaties, and the expectations and policy objectives of contracting states; and a look into the phenomenon of treaty shopping, other perceived improper uses of tax treaties, and the efforts to combat this, including interpretation and application of substance over form principles and domestic legislation and treaty provisions, in particular limitation on benefit provisions. The Improper Use of Tax Treaties will assist advisors in understanding the limits on improper practices. Its historical examination and look at policy will also interest and inform academics and policymakers.

Preface
List of Abbreviations
Introduction
Introductionp. 3
Double Taxation
Occurrence of double taxationp. 9
Rationale for the avoidance of double taxationp. 15
Avoidance of double taxationp. 19
Tax Treaties
History and purposep. 27
Structurep. 37
Improper Use of Tax Treaties
The concept of improper use of tax treatiesp. 95
Treaty shopping and other perceived improper use of tax treatiesp. 119
Efforts to Combat Improper Use of Tax Treaties
Interpretation and application of substance over form principlesp. 163
Provisions in or based on domestic legislationp. 191
Treaty provisionsp. 211
Conclusion and Recommendations
Conclusion and recommendationsp. 257
Bibliographyp. 261
Table of Case Lawp. 271
Indexp. 277
Table of Contents provided by Blackwell. All Rights Reserved.

ISBN: 9789041107374
ISBN-10: 9041107371
Series: Series on International Taxation
Audience: Professional
Format: Hardcover
Language: English
Number Of Pages: 302
Published: March 1998
Country of Publication: NL
Dimensions (cm): 23.39 x 15.6  x 1.75
Weight (kg): 0.6