References

• 2015BEPS Action 6: Tax Treaty Abuse51 cited
• 2010Beneficial Ownership: Current Trends50 cited
• 2016The Multilateral Tax Instrument and Its Relationship with Tax Treaties46 cited
• 2011Tax Treaties and Tax Avoidance: Application of Anti-Avoidance Provisions40 cited
• 2016The Proposed OECD Multilateral Instrument Amending Tax Treaties36 cited
• 2017GAARs and Treaties: From the Guiding Principle to the Principal Purpose Test. What Have We Gained from BEPS Action 6?36 cited
• 2014The 2003 Revision of the OECD Commentaries on the Improper Use of Tax Treaties: A Case for the Declining Effect of the OECD Commentaries?36 cited
• 2015OECD Base Erosion and Profit Shifting Action 6: The General Anti-Abuse Rule30 cited
• 2010The Evolution of the Term “Beneficial Ownership” in Relation to International Taxation over the Past 45 Years25 cited
• 2016Final Report on Action 6 of the OECD/G20 Base Erosion and Profit Shifting Initiative: Prevention of Treaty Abuse22 cited
• 2016A Multilateral Instrument for Implementing Changes to Double Tax Treaties: Problems and Prospects17 cited
• 2013Limitation on Benefits Articles in Income Tax Treaties: The Current State of Play14 cited
• 2017Guidance on the Application of the Principal Purpose Test in Tax Treaties13 cited
• 2017Reconceptionalization of the ‘Immovable Property Clause’ in Article 13 Paragraph 4 OECD Model Convention by Means of the Multilateral Instrument?