The improper use of tax treaties : with particular reference to the Netherlands and the United States
Author(s)
Bibliographic Information
The improper use of tax treaties : with particular reference to the Netherlands and the United States
(Series on international taxation, 19)
Kluwer Law International, 1998
Available at 13 libraries
  Aomori
  Iwate
  Miyagi
  Akita
  Yamagata
  Fukushima
  Ibaraki
  Tochigi
  Gunma
  Saitama
  Chiba
  Tokyo
  Kanagawa
  Niigata
  Toyama
  Ishikawa
  Fukui
  Yamanashi
  Nagano
  Gifu
  Shizuoka
  Aichi
  Mie
  Shiga
  Kyoto
  Osaka
  Hyogo
  Nara
  Wakayama
  Tottori
  Shimane
  Okayama
  Hiroshima
  Yamaguchi
  Tokushima
  Kagawa
  Ehime
  Kochi
  Fukuoka
  Saga
  Nagasaki
  Kumamoto
  Oita
  Miyazaki
  Kagoshima
  Okinawa
  Korea
  China
  Thailand
  United Kingdom
  Germany
  Switzerland
  France
  Belgium
  Netherlands
  Sweden
  Norway
  United States of America
Note
Bibliography: p. 261-269
Includes index
Description and Table of Contents
Description
This reference work presents a detailed and comprehensive study of the improper use of tax treaties. The author provides a brief overview of both the occurrence and avoidance of double taxation and analyzes 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. The concept of the improper use of tax treaties is explored, specifically in the context of the abuse of rights doctrine, the purpose of tax treaties, and the expectations and policy objectives of contracting states. Finally, the book deals with the phenomenon of treaty shopping, other perceived improper uses of tax treaties, and the efforts to combat this. The latter are categorized in interpretation and application of substance over form principles, and domestic legislation and treaty provisions, in particular limitation on benefit provisions.
Table of Contents
Part 1 Double Taxation: Occurrence of double taxation. Rationale for the avoidance of double taxation. Avoidance of double taxation. Part 2 Tax treaties: History and purpose. Structure. Part III Improper Use of Tax Treaties: The concept of improper use of tax treaties. Treaty shopping and other perceived improper use of tax treaties. Part IV Efforts to Combat Improper Use of Tax Treaties: Interpretation - application of substance over form principles. Provisions in or based on domestic legislation. Treaty provisions. Part V Conclusion and Recommendations.
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