References

• 2015BEPS Action 6: Tax Treaty Abuse51 cited
• 2014Qualification of Taxable Entities and Treaty Protection37 cited
• 2004Conflicts of Attribution of Income Involving Trusts under the OECD Model Convention: The Possible Impact of the OECD Partnership Report34 cited
• 2014Tax Incentives and Territoriality within the European Union: Balancing the Internal Market with the Tax Sovereignty of Member States27 cited
• 2014Controlled Foreign Company Legislation, Corporate Residence and Anti-Hybrid Arrangement Rules12 cited
• 2013Intellectual Property Box Regimes: Effective Tax Rates and Tax Policy Considerations12 cited

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