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The Interaction of Domestic Anti-Avoidance Rules with Tax Treaties in the Post-BEPS and Digitalized World
10 references·0 citing·19 second hop
The Interaction of Domestic Anti-Avoidance Rules with Tax Treaties in the Post-BEPS and Digitalized World (2020)The Interaction of Domestic Anti-Avoidanc…Tax Treaty Interpretation After BEPS (2020)Tax Treaty Interpretation Aft…The Meaning of the Principal Purpose Test: One Ring to Bind Them All? (2019)The Meaning of the Principal …Some Reflections on the Saving Clause (2016)Some Reflections on the Savin…BEPS Action 6: Tax Treaty Abuse (2015)BEPS Action 6: Tax Treaty Abu…Germany's Tax Treaty Negotiation Policy (2014)Germany's Tax Treaty Negotiat…Exemption and Tax Credit in German Tax Treaties – Policy and Reality (2010)Exemption and Tax Credit in G…Chapter 3 A Tax Treaty Perspective: Special Issues (2006)Chapter 3 A Tax Treaty Perspe…The Observations on the OECD Commentaries in the Interpretation of Tax Treaties (2005)The Observations on the OECD …Conflicts of Attribution of Income Involving Trusts under the OECD Model Convention: The Possible Impact of the OECD Partnership Report (2004)Conflicts of Attribution of I…Hybrid Science, Medium Vigor (1984)Hybrid Science, Medium VigorThe Legal Effect of Interpretative Declarations (1979)Coordinating the Action of Regional and Global Players during the Shift from Bilateralism to Multilateralism in International Tax Law (2014)Legitimacy and the Making of International Tax Law: The Challenges of Multilateralism (2015)Treaty Abuse in the Post-BEPS World: Analysis of the Policy Shift and Impact of the Principal Purpose Test for MNE Groups (2017)Danish Cases on the Use of Holding Companies for Cross-Border Dividends and Interest – A New Test to Disentangle Abuse from Real Economic Activity? (2020)The PPT in Post-BEPS Tax Treaty Law: It Is a GAAR but Just a GAAR! (2020)Is There an International Minimum Standard on Tax Treaty Shopping after BEPS Action 6? Some Recent Divergent Trends (2022)International Double Taxation of Income: Relief Through International Agreement 1921-1945 (1945)International Tax Coordination for a Second-Best World (Part II) (2010)Avoiding Double Taxation: Credit versus Exemption - The Origins (2012)Current Challenges for EU Controlled Foreign Company Rules (2017)The Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS—Some Thoughts on Complexity and Uncertainty (2018)Switzerland in a Post-BEPS World (2015)Controlled Foreign Corporations as Fiscally Transparent Entities. The Application of CFC Rules in Tax Treaties (2017)International Taxation of Trust Income (2019)OECD Base Erosion and Profit Shifting Action 6: The General Anti-Abuse Rule (2015)The Taxation of Technical Services under the United Nations Model Double Taxation Convention: A Rushed – Yet Appropriate – Proposal for (Developing) Countries? (2015)Output Legitimacy Deficits and the Inclusive Framework of the OECD/G20 Base Erosion and Profit Shifting Initiative (2018)The Proposed Tiebreaker Rule in OECD/G20 BEPS Action 6: A Critical Examination of the Possible Motives and Means, and a Potential Alternative (2016)
this work references cited by second hop

References

  • 2015BEPS Action 6: Tax Treaty Abuse51 cited
  • 2019The Meaning of the Principal Purpose Test: One Ring to Bind Them All?44 cited
  • 2016Some Reflections on the Saving Clause35 cited
  • 2004Conflicts of Attribution of Income Involving Trusts under the OECD Model Convention: The Possible Impact of the OECD Partnership Report34 cited
  • 2006Chapter 3 A Tax Treaty Perspective: Special Issues26 cited
  • 2005The Observations on the OECD Commentaries in the Interpretation of Tax Treaties15 cited
  • 2010Exemption and Tax Credit in German Tax Treaties – Policy and Reality15 cited
  • 2014Germany's Tax Treaty Negotiation Policy14 cited
  • 2020Tax Treaty Interpretation After BEPS13 cited
  • 1984Hybrid Science, Medium Vigor1 cited

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