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Role of the Preamble for the Interpretation of Old and New Tax Treaties and on the Policy of the Prevention of Treaty Abuse
2 references·1 citing·11 second hop
Role of the Preamble for the Interpretation of Old and New Tax Treaties and on the Policy of the Prevention of Treaty Abuse (2020)Role of the Preamble for the Interpretati…A Deconstruction of the Principal Purposes Test (2019)A Deconstruction of the Princ…BEPS Action 6: Tax Treaty Abuse (2015)BEPS Action 6: Tax Treaty Abu…Is There Finally an International Tax System? (2021)Is There Finally an Internati…Treaty Abuse in the Post-BEPS World: Analysis of the Policy Shift and Impact of the Principal Purpose Test for MNE Groups (2017)The Principal Purpose Test (PPT) in BEPS Action 6 and the MLI: Exploring Challenges Arising from Its Legal Implementation and Practical Application (2018)The PPT in Post-BEPS Tax Treaty Law: It Is a GAAR but Just a GAAR! (2020)Value Creation: A Guiding Light for the Interpretation of Tax Treaties? (2020)Is There an International Minimum Standard on Tax Treaty Shopping after BEPS Action 6? Some Recent Divergent Trends (2022)Evaluating International Tax Reform (2003)International Tax as International Law (2007)Base Erosion, Profit Shifting and Developing Countries (2016)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)
this work references cited by second hop

References

  • 2019A Deconstruction of the Principal Purposes Test58 cited
  • 2015BEPS Action 6: Tax Treaty Abuse51 cited

Cited by

  • 2021Is There Finally an International Tax System?16 cited

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