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IFA: Abusive Application of International Tax Agreements - Abusive Application of International Tax Agreements (Paperback)
Loot Price: R2,245
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IFA: Abusive Application of International Tax Agreements - Abusive Application of International Tax Agreements (Paperback)
Series: IFA Congress Series Set
Expected to ship within 10 - 15 working days
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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?
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