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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
Limitation on Benefits Clauses in Double Taxation Conventions

Limitation on Benefits Clauses in Double Taxation Conventions

Borrego, Felix Alberto Vega

Hardcover

Series: Eucotax European Taxation

General Law

ISBN10: 904116135X
ISBN13: 9789041161352
Publisher: Wolters Kluwer Law & Business
Published: Aug 23 2017
Pages: 338
Weight: 1.50
Height: 0.90 Width: 6.40 Depth: 9.80
Language: English

EUCOTAX Series on European Taxation Volume 12

Limitation on Benefits Clauses in Double Taxation Conventions analyses the legal framework and application of limitation on benefits clauses (LOB) in double taxation conventions (DTC), including detailed coverage of major recent developments such as the recent tax treaties concluded between the United States (US) and European Union (EU) Member States, the last version of the US Model Tax Convention (2016), the OECD/G20 project on Base Erosion and Profit Shifting, and relevant new rulings handed down by the European Court of Justice. Upfront planning for international structures is crucial to ensure coverage under bilateral tax treaties. However, as treaty shopping - whereby a third-party national or a corporation sets up a shell company in order to minimize or eliminate income tax - can potentially be facilitated by taking advantage of DTC, companies must carefully scrutinize and comply with requirements found in the LOB clauses in tax treaties. This book studies the specific rules laid down in tax treaties against treaty shopping and, in particular, one type of rule, the LOB.

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