The improper use of tax treaties : with particular reference to the Netherlands and the United States

Stef van Weeghel

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

Abstract

Part 1 Double Taxation: Occurrence of double taxation. Rationale for the avoidance of double taxation. Avoidance of double taxation. Part 2 Tax treaties: History and purpose. Structure. Part III Improper Use of Tax Treaties: The concept of improper use of tax treaties. Treaty shopping and other perceived improper use of tax treaties. Part IV Efforts to Combat Improper Use of Tax Treaties: Interpretation - application of substance over form principles. Provisions in or based on domestic legislation. Treaty provisions. Part V Conclusion and Recommendations.

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