Preventing treaty abuse

Sinopse

The OECD initiative on Base Erosion and Profit Shifting (BEPS) has put the issue of treaty abuse and the means to counter it on top of the global political agenda. Preventing treaty abuse is therefore one of the most debated topics in international tax law. Diverging national legal traditions in combatting abuse both under domestic and tax treaty law have led to a globally diversified legal framework in this respect and make the OECD's agenda to harmonize these attempts even more challenging. This book provides a collection of master theses focussing on preventing treaty abuse. The aim of the book is to analyse the notion of treaty abuse, its historical roots and the measures to counter it. The topics cover a wide range of both policy and legal issues.