Role of the Preamble for the Interpretation of Old and New Tax Treaties and on the Policy of the Prevention of Treaty Abuse

Luc De Broe

19 citations0/0 files storedBulletin for international taxation

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Taxation and Legal Issues Corporate Taxation and Avoidance International Law and Aviation

Abstract

This article examines the effect of the preamble of tax treaties before and after the amendments made to the OECD Model (2017) on the interpretation of tax treaties with the aim of preventing their abuse.

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2019A Deconstruction of the Principal Purposes Test 2015BEPS Action 6: Tax Treaty Abuse

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2021Is There Finally an International Tax System?

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