This study considers how tax authorities attempt to strike down international tax avoidance structures in particular those involving the use of conduit and base companies set up by third country residents for purposes of “treaty shopping” and “EC-Directive shopping”. The book essentially focuses on the interaction between provisions and judicially developed doctrines of domestic tax law preventing international tax avoidance, on the one hand, and norms of international law, in particular tax treaties and rules of Community law, on the other hand. View sample chapter    |    View table of contents This book also considers the treaty based anti-avoidance measures such as “beneficial ownership” - requirement and “limitation on benefits” - provisions. This part of the study is truly comparative, analyzing the case law of Australia, Austria, Belgium, Canada, the Czech Republic, Finland, France, Germany, India, Switzerland, the United Kingdom and the United States.

Main Contents

• Part One: The use of Conduit & Base Companies in International Tax Planning.
• Part Two: Prevention of Abuse under Belgian Domestic Law.
• Part Three: Conduit & Base Companies Prevention of Abuse under Belgian Tax Treaties.
• Part Four: Conduit & Base Companies Prevention of Abuse under Community Law.

• Vol. 1 - The Concept of Income: A Multi-Disciplinary Analysis

      by Kevin Holmes

• Vol. 2 - Taxing Portfolio Income in Global Financial Markets

      by Doron Herman

• Vol. 3 - Free Movement of Persons and Income Tax Law
  by Servaas van Thiel
• Vol. 4 - Advance Tax Rulings and Principles of Law
  by Carlo Romano
• Vol. 5 - Arbitration under Tax Treaties
  by Mario Züger
• Vol.6 - E-Commerce and Source-Based Income Taxation

      by Dale Pinto

• Vol. 7 - Interpretation of Tax Treaties under International Law
  by Frank Engelen
• Vol. 8 - Taxation of Investment Funds in the European Union
  by Tomi Viitala
• Vol. 9 - Taxation of Cross-Border Partnerships
  by Jesper Barenfeld
• Vol. 10 - Taxation of International Performing Artistes
  by Dick Molenaar
• Vol. 11 - Dispute Resolution under Tax Treaties
  by Zvi Daniel Altman
• Vol. 12 - Income from International Private Employment
  by Frank Pötgens
• Vol. 13 - Taxation of Investment Derivatives

      by Antti Laukkanen