Store International IFA: How Domestic Anti-Avoidance Rules Affect Double Taxation Conventions
IFA: How Domestic Anti-Avoidance Rules Affect Double Taxation Conventions

IFA: How Domestic Anti-Avoidance Rules Affect Double Taxation Conventions

By International Fiscal Association (IFA)
Format
Softcover
$71.00

Softcover

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Overview
The question of whether there are internationally recognized anti-avoidance rules that are applied to tax treaties involves two subsidiary questions: (1) Whether international law recognizes the concept of abuse of rights, fraus legis (2) Whether this concept of abuse of rights, fraus legis, the business purpose test, etc., can be applied to tax treaties.

The book then turns to the question of whether provisions included in the tax code that are expressly designed to re-characterize or deal with transactions that are considered to result in unacceptable avoidance of tax under the code can be extended and applied where there is an unacceptable avoidance of tax by virtue of the application of a tax treaty provision.

Publish Date 09/01/1995
Product Line Kluwer Law International
ISBN 9789041100702
SKU 10057881-0001
Table of Contents
  1. Proceedings of the Seminar
  2. Addendum: Proposed Section 7701 (1) Regulations
Volumes