How domestic anti-avoidance rules affect double taxation conventions : proceedings of a seminar held in Toronto, Canada, in 1994 during the 48th Congress of the International Fiscal Association
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書誌事項
How domestic anti-avoidance rules affect double taxation conventions : proceedings of a seminar held in Toronto, Canada, in 1994 during the 48th Congress of the International Fiscal Association
（IFA Congress seminar series, v. 19c）
Kluwer Law International, c1995
- pbk. : alk. paper
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Includes index
内容説明・目次
内容説明
The question of whether there are internationally recognized anti-avoidance rules that are applied to tax treaties involves two subsidiary questions: whether international law recognizes the concept of abuse of rights, and whether this concept of abuse of rights can be applied to tax treaties. The book then turns to the question of whether provisions included in the tax code that are expressly designed to re-characterize or deal with transactions that are considered to result in unacceptable avoidance of tax under the code can be extended and applied where there is an unacceptable avoidance of tax by virtue of the application of a tax treaty provision.
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