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  • Open Daily: 10am - 10pm
    Alley-side Pickup: 10am - 7pm

    3038 Hennepin Ave Minneapolis, MN
    612-822-4611

Open Daily: 10am - 10pm | Alley-side Pickup: 10am - 7pm
3038 Hennepin Ave Minneapolis, MN
612-822-4611
The Improper Use of Tax Treaties, with Particular Reference to the Netherlands and the United States

The Improper Use of Tax Treaties, with Particular Reference to the Netherlands and the United States

Van Weeghel, Stef
Weeghel, Stef Van
Weeghel, S. Van

Hardcover

Series: Series on International Taxation, Book 19

General LawInternational Relations

Currently unavailable to order

ISBN10: 9041107371
ISBN13: 9789041107374
Publisher: Kluwer Law International
Published: Mar 27 1998
Pages: 304
Weight: 1.32
Height: 0.69 Width: 6.14 Depth: 9.21
Language: English
In the modern international tax world, tax advisors may assist their clients in using tax treaties in a manner clearly contrary to the treaties intent. With the right guidance, investors can determine which treaties offer the most beneficial access to the company of the desired investment. Investors have been known to go so far as to quickly set up corporations in countries with no connection to themselves or to the target country, simply to take advantage of a particular treaty network. In response, governments have sought means to curb these and other improper' tax treaty practices. This reference work offers a detailed and comprehensive study of the improper use of tax treaties. The author's examination includes: a concise overview of both the occurrence and avoidance of double taxation; an analysis of 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; an exploration of the concept of the improper use of tax treaties specifically in the context of the abuse of rights doctrine, the purpose of tax treaties, and the expectations and policy objectives of contracting states; and a look into the phenomenon of treaty shopping, other perceived improper uses of tax treaties, and the efforts to combat this, including interpretation and application of substance over form principles and domestic legislation and treaty provisions, in particular limitation on benefit provisions. The Improper Use of Tax Treaties will assist advisors in understanding the limits on improper practices. Its historical examination and look at policy will also interest and inform academics and policymakers.

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