The Interaction of Domestic Anti-Avoidance Rules with Tax Treaties in the Post-BEPS and Digitalized World

Vikram K. Chand · Craig Macfarlane Elliffe

12 citations0/0 files storedBulletin for international taxation

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Taxation and Legal Issues Economic and Fiscal Studies Corporate Taxation and Avoidance

Abstract

In its analysis, this article distinguishes between domestic anti-avoidance rules that counteract treaty abuse and those that thwart abuse of domestic law. The authors conclude that conflicts could arise with tax treaties. States should employ a provision that authorizes the application of these rules to prevent this situation arising.

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2015BEPS Action 6: Tax Treaty Abuse 2019The Meaning of the Principal Purpose Test: One Ring to Bind Them All?2016Some Reflections on the Saving Clause 2004Conflicts of Attribution of Income Involving Trusts under the OECD Model Convention: The Possible Impact of the OECD Partnership Report 2006Chapter 3 A Tax Treaty Perspective: Special Issues 2010Exemption and Tax Credit in German Tax Treaties – Policy and Reality 2005The Observations on the OECD Commentaries in the Interpretation of Tax Treaties 2014Germany's Tax Treaty Negotiation Policy

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