Domestic anti-abuse rules and double taxation treaties : a Spanish perspective - part I

The study of the interaction of anti-abuse clauses with tax treaties is complex and needs to consider multiple factors. This first part of an article in a series of two, examines the problem not only from a pure international law perspective (which encompasses the OECD Model Tax Convention), but also - due to the close relationship between international law and national law in this field - from the perspective of Spain's tax system.