How “Limited” Is Limited Force of Attraction? An Analysis of the Relevant Case Law and the Potential Implications of the OECD/G20 BEPS Initiative

This article considers the scope of the limited force of attraction principle as set out in article 7 of the UN Model, focusing on its development, the relevant case law and the potential implications for the principle in the light of the OECD/G20 Base Erosion and Profit Shifting initiative.