Anti Abuse Rules and Tax Treaties is popular PDF and ePub book, written by Georg Kofler et al. in 2024-06-24, it is a fantastic choice for those who relish reading online the Law genre. Let's immerse ourselves in this engaging Law book by exploring the summary and details provided below. Remember, Anti Abuse Rules and Tax Treaties can be Read Online from any device for your convenience.
Anti Abuse Rules and Tax Treaties Book PDF Summary
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. The conflicts and other legal difficulties that inevitably result deserve intensive scrutiny. This book provides an in-depth analysis of current issues concerning the relations of various anti-abuse rules to each other and their impact on the application of tax treaties. The topics include the following: 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 offers an in-depth analysis of a particular topic, drawing on the most recent scientific research. This is the only book available to offer such a wide-ranging, detailed, and practical analysis of how the full range of anti-abuse rules interacts with tax treaties. It will prove of immeasurable value to 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.
Detail Book of Anti Abuse Rules and Tax Treaties PDF
- Author : Georg Kofler et al.
- Release : 24 June 2024
- Publisher : Kluwer Law International B.V.
- ISBN : 9789403526683
- Genre : Law
- Total Page : 492 pages
- Language : English
- PDF File Size : 17,9 Mb
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