Anti-Abuse Measures in Tax Treaties Following the OECD Multilateral Instrument - Part 1

C. Bergedahl

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

Abstract

In Part 1 of this article, the author examines the effects of the inclusion of anti-abuse measures in tax treaties following the implementation of the OECD Multilateral Instrument, together with the implications of this for the OECD Base Erosion and Profit Shifting initiative.

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2015BEPS Action 6: Tax Treaty Abuse 2010Beneficial Ownership: Current Trends 2016The Multilateral Tax Instrument and Its Relationship with Tax Treaties 2011Tax Treaties and Tax Avoidance: Application of Anti-Avoidance Provisions 2016The Proposed OECD Multilateral Instrument Amending Tax Treaties 2017GAARs and Treaties: From the Guiding Principle to the Principal Purpose Test. What Have We Gained from BEPS Action 6?2014The 2003 Revision of the OECD Commentaries on the Improper Use of Tax Treaties: A Case for the Declining Effect of the OECD Commentaries?2015OECD Base Erosion and Profit Shifting Action 6: The General Anti-Abuse Rule

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