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International Tax Planning and Prevention of Abuse

A Study under Domestic Tax Law, Tax Treaties and EC Law in relation to Conduit and Base Companies.
 
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Title:

International Tax Planning and Prevention of Abuse

Series:

Volume 14 in the Doctoral Series

Author(s):
Date of publication:
ISBN:

978-90-8722-035-8

Type of publication:

Print Book

Number of pages:

1,144

Terms:

Shipping fees apply. View shipping information

Price:
EUR 150 / USD 195 (VAT excl.)
Order Print
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Title:

International Tax Planning and Prevention of Abuse

Series:

Volume 14 in the Doctoral Series

Author(s):
Date of publication:
ISBN:

978-90-8722-035-8

Type of publication:

Online book

Number of pages:

1,144

Access:

Up to five users. View purchase information

Price:
EUR 150 / USD 195 (VAT excl.)
Order Online book
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International Tax Planning and Prevention of Abuse

Why this book?

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.

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.
 

Downloads

 

This book is part of the IBFD Doctoral Series

Downloads

 

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

 

 

Author(s)

Luc De Broe is a professor of tax law at the Katholieke Universiteit of Leuven and practices international tax law with Stibbe in Brussels.
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