Treaty Shopping Taxation | Keyword Rankings

Google Keyword Rankings for : treaty shopping taxation

1 Action 6 – Prevention of Tax Treaty Abuse - OECD
https://www.oecd.org/tax/beps/beps-actions/action6/
Treaty shopping typically involves the attempt by a person to access indirectly the benefits of a tax agreement between two jurisdictions without being a ...
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2 What is Treaty Shopping - International Taxation - Sorting Tax
https://sortingtax.com/what-is-treaty-shopping/
Treaty shopping is defined as routing of income arising in Source country, to a person in another country (country of residence), through an intermediary ...
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3 Income Tax Treaty Shopping
https://scholarlycommons.law.northwestern.edu/cgi/viewcontent.cgi?article=1154&context=njilb
While treaty shopping often encompasses instances of tax evasion as well as tax avoidance, 13 this Comment focuses on legal forms of treaty shopping and the ...
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4 Navigating optimal treaty-shopping routes using a multiplex ...
https://www.ncbi.nlm.nih.gov/pmc/articles/PMC8396775/
Treaty shopping involves searching for favorable tax treaties for the purpose of tax avoidance. This is possible because there are significant ...
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5 “Time Present and Time Past:” U.S. Anti-Treaty Shopping ...
https://www.americanbar.org/groups/taxation/publications/tax_lawyer_home/16fal/macdonald/
This Article comprehensively discusses U.S. anti-treaty shopping (limitation on benefits) rules contained in U.S. income tax treaties up to ...
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6 Tax Effects of Treaty Shopping and OECD's BEPS Implications
https://journals.sagepub.com/doi/full/10.1177/2319714520907245
Luc De Broe (2008) states that 'treaty shopping concerns a situation in which a person who is not entitled to the benefits of a tax treaty makes ...
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7 International Tax Planning and Prevention of Abuse - IBFD
http://www.ibfd.org/sites/default/files/2021-12/International%20Tax%20Planning%20and%20Prevention%20of%20Abuse.pdf
in treaty shopping: claiming an otherwise unavailable reduction or exemption of. (withholding) taxes in the source State of the income; ...
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8 Opinion piece: Taking action to stop tax treaty shopping
https://ministers.treasury.gov.au/ministers/andrew-leigh-2022/articles/opinion-piece-taking-action-stop-tax-treaty-shopping
Treaty shopping is just one of the tax avoidance practices that have caught the fancy of multinationals. Apple pioneered 'Leprechaun Economics'.
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9 Rethinking Treaty Shopping: Lessons for the European Union
https://repository.law.umich.edu/cgi/viewcontent.cgi?referer=&httpsredir=1&article=1077&context=book_chapters
Finally, we examine the possible implications of EU law on the treaty shopping debate. 2. Treaty shopping and improper use of tax treaties. 2.1. Finding the ...
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10 Solving the Problem of Tax-Treaty Shopping through the Use ...
https://scholarship.richmond.edu/cgi/viewcontent.cgi?article=1085&context=global
(providing a list of tax treaties in effect), available at 2007 WL 4986573 (I.R.S.). 13 Georg W. Koefler & Ruth Mason, Double Taxation: A European "Switch in.
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11 Treaty Shopping - Income Taxes - Explanations
https://answerconnect.cch.com/document/arp28d0be81747b6d1000a909001b78be8c7802bc/federal/irc/explanation/treaty-shopping
The publicly traded exception to treaty shopping provides that a foreign corporation that is wholly owned by a domestic corporation whose stock is primarily and ...
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12 Treaty shopping and prevention in a post-BEPS world: Part I
https://www.internationaltaxreport.com/investment-and-indirect-taxes/treaty-shopping-and-prevention-in-a-post-beps-world-part-i-126400.htm
Treaty shopping is essentially facilitated by two strongly connected legal fictions: the idea of a legal entity as a separate taxable person and ...
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13 Tax Treaty Tables | Internal Revenue Service
https://www.irs.gov/individuals/international-taxpayers/tax-treaty-tables
The United States has income tax treaties (or conventions) with a number of foreign countries under which residents (but not always ...
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14 4. Conclusion and next steps | Prevention of Treaty Abuse ...
https://www.oecd-ilibrary.org/sites/47e6ecc2-en/index.html?itemId=/content/component/47e6ecc2-en
36. The minimum standard on treaty shopping requires jurisdictions to include two components in their tax agreements: an express statement on non-taxation ( ...
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15 Australia: ATO guidance on treaty shopping arrangements
https://home.kpmg/us/en/home/insights/2022/07/tnf-australia-ato-guidance-on-treaty-shopping-arrangements.html
The guidance—TA 2022/2 (Treaty shopping arrangements to obtain reduced withholding tax rates)—expresses the ATO's concerns relating to ...
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16 The Unintended Consequences of Bilateralism: Treaty ...
https://www.cambridge.org/core/journals/international-organization/article/unintended-consequences-of-bilateralism-treaty-shopping-and-international-tax-policy/ECBFC8B2F2486DCDDF3D25DD202CFFC7
The extent to which treaty shopping constrains governments' ability to tax depends on the structure of the treaty network. When two countries ...
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17 Doing Business in the United States: US tax treaties - PwC
https://www.pwc.com/us/en/services/tax/us-inbound-tax/doing-business-in-the-united-states/us-tax-treaties.html
to reduce or eliminate double taxation and excessive taxation. US income tax treaties typically cover various categories of income, including: business profits ...
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18 Treaty shopping - - Transfer Pricing Case
https://tpcases.com/tag/treaty-shopping/
An analysis of tax treaty provisions to structure an international transaction or operation so as to take advantage of a particular tax treaty.
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19 Double Taxation, Tax Treaties, Treaty Shopping and the ...
https://www.amazon.com/Taxation-Treaties-Shopping-European-Community/dp/9041126589
Double Taxation, Tax Treaties, Treaty Shopping and the European Community (Eucotax Series on European Taxation, 15) ... The List Price is the suggested retail ...
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20 Profitable Detours: Network Analysis of Tax Treaty Shopping
https://www.ntanet.org/wp-content/uploads/proceedings/2015/003-riet-lejour-profitable-detours-network-analysis-treaty.pdf
Keywords: corporate taxation, tax treaties, treaty shopping, tax havens, ... We compute the potential tax reduction by treaty shopping on repatriated.
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21 Treaty Shopping and International Tax Policy - JSTOR
https://www.jstor.org/stable/44651944
maintain lower tax rates. The global investment regime, the international tax system, and much of world trade are governed by bilateral treaties. Received ...
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22 Treaty abuse and treaty shopping - UN Digital Library
https://digitallibrary.un.org/record/591910?ln=en
that, in considering the issue of treaty abuse, there was a balance between the need to provide certainty for investors and the need for tax administrations to ...
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23 Double Taxation Treaties and Treaty Shopping Introduction
http://vivaafricallp.com/wp-content/uploads/2017/03/Newsletter-Volume-XXXII-Double-Taxation-and-Treaty-Shopping.pdf
Double Taxation Treaties and Treaty Shopping. Introduction. A Double Taxation Treaty (DTT) is an agreement of an international nature entered into.
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24 Treaty Shopping and the New Multilateral Tax Agreement—Is ...
https://digitalcommons.schulichlaw.dal.ca/cgi/viewcontent.cgi?article=2135&context=dlj
Catherine Anne Brown and Joseph Bogle, "Treaty Shopping and the New Multilateral Tax Agreement—Is it. Business as Usual in Canada?" (2020) 43:1 ...
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25 Senate Executive Report 111-3 - TAX CONVENTION WITH ...
https://www.govinfo.gov/content/pkg/CRPT-111erpt3/html/CRPT-111erpt3.htm
The Convention contains rigorous protections designed to protect against ``treaty shopping,'' which is the inappropriate use of a tax treaty by ...
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26 The Cost and Benefits of Tax Treaties with Investment Hubs
https://www.imf.org/-/media/Files/Publications/WP/2018/wp18227.ashx
theoretical model, the paper investigates the role of treaty shopping in driving ... Keywords: Tax Treaty Policy, Double Tax Treaties, Domestic Resource ...
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27 2019 Outlook: 'End of Treaty Shopping' for Multinationals
https://news.bloombergtax.com/transfer-pricing/2019-outlook-end-of-treaty-shopping-for-multinationals
The instrument is designed to bring bilateral tax treaties up to date with new, stricter global standards much more quickly and efficiently than ...
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28 action item 6: - attacking treaty shopping - Publications
http://publications.ruchelaw.com/news/2014-10/Vol.1No.9-6_BEPS_Action_6-Treaty_Abuse.pdf
Double Non-taxation. GAAR. General Anti-Avoidance Rule. Limitation on Benefits. L.O.B.. P.P.T.. Principal Purpose Test. Treaty Abuse. Treaty Shopping.
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29 Treaty shopping | Lund University
https://www.lunduniversity.lu.se/lup/publication/1560781
When treaty shopping, one uses double taxation treaties (and/or domestic tax law) to gain advantages otherwise not applicable. A double taxation convention ...
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30 Taxpayer Alert issued on treaty shopping arrangements
https://www.ato.gov.au/Business/Business-bulletins-newsroom/Public-advice-and-guidance/Taxpayer-Alert-issued-on-treaty-shopping-arrangements/
TA 2022/2 outlines our concerns about arrangements which inappropriately access treaty benefits to obtain a tax advantage.
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31 What Is Tax Treaty Shopping? How LOB Provisions Curb Abuse
https://www.lawofficesofjasonknott.com/what-is-tax-treaty-shopping-how-lob-provisions-curb-abuse/
Without a tax treaty, a company engaged in business between two countries might find itself liable for income taxes in both countries on the ...
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32 Reconsidering the Application and Interpretation of Anti-treaty ...
https://kluwerlawonline.com/journalarticle/Intertax/44.3/TAXI2016016
One of the most common strategies to usetax treaties as a tax planning tool is treaty shopping. Thetraditional approach as regards this topic is to follow the ...
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33 Tax Treaty Shopping in Ethiopia: The Need to Integrate Anti ...
https://heinonline.org/hol-cgi-bin/get_pdf.cgi?handle=hein.journals/bahirdjl11§ion=16
income tax law and double taxation avoidance agreements. Accordingly, the findings show that tax treaty shopping is not sufficiently regulated under the ...
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34 Treaty Shopping - Jus Mundi
https://jusmundi.com/en/document/wiki/en-treaty-shopping
1. A phenomenon originally known in the field of international tax matters, 1 treaty shopping (sometimes called ...
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35 Tax treaties: Boost or Bane for Development?
https://blogs.worldbank.org/governance/tax-treaties-boost-or-bane-development
Tax authorities, particularly in developing countries, are finding it hard to counter such “treaty shopping.”
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36 Text - Treaty Document 111-7 - Tax Convention with Hungary
https://www.congress.gov/treaty-document/111th-congress/7/document-text
For example, the proposed Convention contains comprehensive provisions designed to address ``treaty shopping,'' which is the inappropriate use of a tax ...
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37 Tax treaty - Wikipedia
https://en.wikipedia.org/wiki/Tax_treaty
Many countries have entered into tax treaties with other countries to avoid or mitigate double taxation. Such treaties may cover a range of taxes including ...
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38 Countries continue to permit tax treaty shopping despite BEPS ...
https://mnetax.com/countries-continue-to-permit-tax-treaty-shopping-despite-beps-promises-oecd-report-reveals-43292
The minimum standard on tax treaty shopping is a means to prevent tax avoidance by multinationals. It addresses attempts to indirectly ...
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39 Beneficial ownership: Treaty shopping - HMRC internal ...
https://www.gov.uk/hmrc-internal-manuals/international-manual/intm504010
Treaty shopping involves the improper use of a DTA, whereby a person acts through an entity created in another state with the main or sole ...
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40 Australian Taxation Office issues Taxpayer Alert on treaty ... - EY
https://www.ey.com/en_gl/tax-alerts/australian-taxation-office-issues-taxpayer-alert-on-treaty-shopping-arrangements-to-obtain-reduced-withholding-tax-rates
The TA provides examples of treaty shopping arrangements that the ATO views as higher-risk arrangements which will warrant increased scrutiny by ...
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41 Treaty shopping Archives - Kluwer International Tax Blog
http://kluwertaxblog.com/category/treaty-shopping/
Even before introduction of the BEPS PPT, the UK has had purpose-based provisions in various forms, designed to limit access to treaty benefits in its ...
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42 Tax treaty shopping: structural determinants ... - Francis Weyzig
https://francisweyzig.files.wordpress.com/2013/05/weyzig-tax-treaty-shopping-20120810.pdf
taxes. This is referred to as tax treaty shopping. The Netherlands is the world's ... Keywords Treaty shopping, Tax treaties, Foreign direct investment, ...
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43 TREATY SHOPPING AND THE ABUSE OF INCOME TAX ...
https://central.bac-lac.gc.ca/.item?id=TC-QMM-83949&op=pdf&app=Library&oclc_number=894086444
Treaty shopping violates the rationale for the allocation of taxing rigbts under a tax treaty. 95. Planning to circumvent the application of anti-treaty ...
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44 New international pact launched to end tax 'treaty shopping'
https://www.reuters.com/article/us-oecd-tax/new-international-pact-launched-to-end-tax-treaty-shopping-idUSKBN18Y2SL
› article › us-oecd-tax › new-i...
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45 (PDF) Tax treaty shopping: Structural determinants of Foreign ...
https://www.researchgate.net/publication/257574639_Tax_treaty_shopping_Structural_determinants_of_Foreign_Direct_Investment_routed_through_the_Netherlands
Many multinationals divert Foreign Direct Investment (FDI) through conduit countries that have a favorable tax treaty network, to avoid host ...
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46 Treaty shopping: tax planning in the international field or form ...
https://link.gale.com/apps/doc/A372554683/AONE?u=googlescholar&sid=AONE&xid=fa76eab9
First, it has been argued that treaty-shopping is a method of tax avoidance and, as such, improper and contrary to the purposes of tax treaties. It has also ...
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47 Treaty-shopping is about to get more expensive | The Economist
https://www.economist.com/finance-and-economics/2018/11/24/treaty-shopping-is-about-to-get-more-expensive
Double-taxation treaties (DTTs) specify the rate applied by source ... Rather, they have led to “treaty-shopping”, with firms merely ...
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48 Tax treaty shopping: structural determinants of Foreign Direct ...
https://econpapers.repec.org/RePEc:kap:itaxpf:v:20:y:2013:i:6:p:910-937
By Francis Weyzig; Abstract: Many multinationals divert Foreign Direct Investment (FDI) through conduit countries that have a favorable tax ...
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49 Unraveling the United States- Japan Income Tax Treaty and a ...
https://sftaxcounsel.com/income-tax-treaty-2/
The major purpose of an income tax treaty is to mitigate international double taxation through tax reduction or exemptions on certain types ...
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50 The Israeli Tax Authority on Treaty Shopping - אבי נוב
http://www.israeltaxlaw.com/page671.asp
Treaty Shopping is said to exist if a resident of a particular country takes steps to establish an entity such as a company in another country, with the aim of ...
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51 Treaty shopping - Findex
https://www.findex.com.au/insights/article/treaty-shopping
Broadly, treaty shopping refers to a contrived arrangement designed to obtain a reduced rate of withholding tax (WHT) under a double-tax ...
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52 Mechanisms to Fight Treaty Abuse: An overview - IBDT
https://www.ibdt.org.br/RDTIA/n-7-2020/mechanisms-to-fight-treaty-abuse-an-overview/
Treaty shopping refers to any situation where a taxpayer who is not a resident of a State tries to obtain the benefits granted by a tax treaty concluded by ...
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53 TREATY SHOPPING - The Law Brigade Publishers
http://thelawbrigade.com/wp-content/uploads/2019/05/Arthya.pdf
multinational companies have stared abusing double taxation avoidance treaties by the method of 'treaty shopping'. Treaty shopping means analysis of tax ...
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54 Treaty-shopping - The South Centre
https://www.southcentre.int/tag/treaty-shopping/
Tax Cooperation Policy Brief 18, September 2021 ... – it cannot reasonably be considered that one of the principal purposes of the arrangement or transaction is ...
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55 Tax Insights ATO releases Taxpayer Alert on treaty shopping ...
https://www2.deloitte.com/content/dam/Deloitte/au/Documents/tax/deloitte-au-tax-insights-ato-releases-taxpayer-alert-treaty-shopping-arrangements-210722.pdf
On 20 July 2022, the Australian Taxation Office (ATO) published Taxpayer Alert TA 2022/2 on “treaty shopping arrangements designed to ...
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56 Tag: Treaty shopping - TP Guidelines
https://tpguidelines.com/tag/treaty-shopping/
Treaty shopping thus upsets the balance and reciprocity of the tax treaty: in order to preserve a tax treaty's inherent reciprocity, its benefits must not be ...
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57 ATO issues guidance on treaty shopping arrangements
https://www.bdo.global/en-gb/microsites/tax-newsletters/corporate-tax-news/issue-63-august-2022/australia-ato-issues-guidance-on-treaty-shopping-arrangements
Treaty shopping usually involves the interposition of one or more related entities between an Australian resident and the ultimate recipient of the dividends or ...
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58 Limitation on Benefits Provisions | US Tax Treaties
https://freemanlaw.com/limitation-on-benefits/
Such so-called “treaty shopping” concerns have given rise to the limitation-on-benefits clauses set out in U.S. tax treaties, which are one of the Treasury ...
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59 What is Treaty Shopping? - GKToday
https://www.gktoday.in/topic/what-is-treaty-shopping/
The bilateral tax treaties are done to reciprocate the benefits between the residents of two countries but when someone from a third country ...
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60 Article 16 of the 1977 United States Model Treaty
https://digitalcommons.law.uga.edu/cgi/viewcontent.cgi?referer=&httpsredir=1&article=1816&context=gjicl
sury), this practice is known as "treaty shopping" and is an unin- ... 16 during the ratification process of the Argentina tax treaty. 5 In.
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61 Effects of Blocking Treaty Shopping Routes in the Tax Treaty ...
https://www.researchsquare.com/article/rs-1268442/v1.pdf
This is where treaty shopping, the process of nding advantageous tax treaties, comes into the picture (Weyzig 2013). Multinationals engage in ...
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62 Responses to Tax Treaty Shopping: A Comparative Evaluation
https://papers.ssrn.com/sol3/papers.cfm?abstract_id=1688689
Regarding many of these arrangements as abusive treaty shopping, the OECD and several member jurisdictions have adopted various responses to ...
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63 Unilateral Responses to Tax Treaty Abuse
https://scholarship.law.ufl.edu/cgi/viewcontent.cgi?article=1780&context=facultypub
Treaty Shopping Across Multiple Treaties: Renegotiate ... face of overwhelming evidence of treaty abuse, tax treaties are. 1. See REUVEN AVI-YONAH, ...
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64 United States Model Technical Explanation of November 15 ...
https://home.treasury.gov/system/files/131/Treaty-US-Model-TE-2006.pdf
country under the provisions of a tax treaty between the United States and the ... The use of facilities solely to store, display or deliver.
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65 The Harmonization of Tax Treaties and Domestic Law
https://digitalcommons.law.byu.edu/cgi/viewcontent.cgi?article=1087&context=ilmr
It specifically addresses (A) treaty abuse and shopping, (B) interpretative issues, and (C) international treaty override by domestic.
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66 Alta Energy: The Supreme Court Of Canada Rules On Tax ...
https://www.jdsupra.com/legalnews/alta-energy-the-supreme-court-of-canada-1566601/
Alta Energy: The Supreme Court Of Canada Rules On Tax Treaty Shopping ... On November 26, 2021, the Supreme Court of Canada (“SCC”) released its ...
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67 Objective or Subjective – Anti-treaty shopping policy in select ...
https://www.taxacademy.sg/files/research-papers/Objective%20or%20Subjective%20-%20Anti-treaty%20shopping%20policy.pdf
The 'principal' purpose of tax treaties remained the prevention of double taxation, see B.J. Arnold, “Tax Treaties and Tax Avoidance: The 2003 Revisions to the ...
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68 Schwarz on Tax Treaties, Sixth Edition - Wolters Kluwer
https://law-store.wolterskluwer.com/s/product/schwarz-on-tax-treaties-6e/01t4R00000OTzEL
Schwarz on Tax Treaties, now in its sixth edition, is the definitive analysis of tax ... CHAPTER 17 Treaty Shopping and Other Avoidance.
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69 Alta Energy ‎—‎ FCA confirms treaty shopping not abusive
https://www.dlapiper.com/en/canada/insights/publications/2020/03/federal-court-confirms-treaty-shopping-not-abusive/
The GAAR applies where a transaction results in a tax benefit, is not undertaken for primarily bona fide non-tax purposes, and is abusive of the ...
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70 New tax code to stop treaty shopping - The Economic Times
https://m.economictimes.com/news/economy/policy/new-tax-code-to-stop-treaty-shopping/articleshow/3871783.cms
Code likely by year-end, may include provision for preventing misuse of double taxation avoidance treaties.
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71 OECD Treaty Limit Shopping | Cross Border Accountant
https://www.aslcpa.com/tax-articles/oecd-moves-limit-treaty-shopping/
The Action 6 minimum standard requires that countries' tax treaties include a statement clarifying that the treaty isn't intended to allow nontaxation or ...
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72 Tax treaty shopping: structural determinants of ... - Springer Link
https://link.springer.com/article/10.1007/s10797-012-9250-z
Tax treaty shopping is a particular form of tax avoidance by multinational corporations. It involves the diversion of Foreign Direct ...
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73 Top Court Blesses Treaty-Shopping Arrangement: The Alta ...
https://www.dwpv.com/en/insights/publications/2021/top-court-blesses-treaty-shopping-arrangement
The minority suggested that treaty-shopping is abusive when taxing rights are allocated on the basis of economic allegiance and conduit entities ...
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74 Tax Treaty Legislation in the 111th Congress: Explanation and ...
https://www.everycrsreport.com/files/20100317_R40468_a74038cab84d648090c7b136474e3c1928a01f9e.pdf
“Treaty shopping” occurs where a foreign parent firm in one country receives its U.S.-source income through an intermediate subsidiary in a ...
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75 Double Taxation, Tax Treaties, Treaty Shopping ... - Goodreads
https://www.goodreads.com/book/show/4317493-double-taxation-tax-treaties-treaty-shopping-and-the-european-communit
Not only does it create economic distortions and breach the principle of neutrality of taxation but it also constitutes a major obstacle to ...
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76 The MLI wipes out Indian jurisprudence on treaty shopping
https://www.internationaltaxreview.com/article/2a6a5kj0p2b6ojikoo6ps/the-mli-wipes-out-indian-jurisprudence-on-treaty-shopping
The preamble of the MLI states that existing tax treaties should not create opportunities for tax avoidance and evasion. This could expose ...
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77 Tax Treaty Shopping Definition
https://www.murphyinc.org/wp-content/uploads/formidable/13/tax-treaty-shopping-definition.pdf
Tax Treaty Shopping Definition. Surest Jerrie disillusion ridiculously while Mitch always queuings his Harvard deters occidentally, he mollycoddle so ...
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78 Attention Treaty Shoppers Beps Mli Takes Effect July-1-2018
https://www.globetax.com/attention-treaty-shoppers-beps-mli-takes-effect-july-1-2018-2/
Of the fifteen Actions, No. 6 is most directly applicable to GlobeTax and withholding tax recovery. Titled “Preventing the Granting of Treaty Benefits in ...
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79 Explanation of proposed protocol to the income tax treaty ...
https://www.jct.gov/CMSPages/GetFile.aspx?guid=b19f450c-9aad-4906-b872-49d67326b2c5
jrotocol would amend the current U.S.-Belgium income tax treaty, ... eaties, but is somewhat less strict than the anti-treaty shopping.
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80 ATO explains treaty shopping — Orbitax Tax News & Alerts
https://www.orbitax.com/news/archive.php/Treaty--between-Australia-and--144
The Interpretative Decision goes on to say that as the holding company was established before the tax treaty came into force and there is no other evidence of ...
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81 From treaty shopping to FAPI and transfer pricing
https://www.osler.com/en/resources/cross-border/2020/from-treaty-shopping-to-fapi-and-transfer-pricing-notable-international-tax-cases
(2020 FCA 43), the FCA concluded that the general anti-avoidance rule (GAAR) in the Income Tax Act (Tax Act) did not apply where the taxpayer, a Luxembourg- ...
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82 A COMMON WITHHOLDING TAX
https://feps-europe.eu/wp-content/uploads/2020/09/A-Common-Withholding-Tax-for-the-EU.pdf
differences in withholding taxes on dividend, interest and royalties on outgoing intra-firm income flows. This is called treaty shopping.
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83 9789041126580: Double Taxation, Tax Treaties ... - AbeBooks
https://www.abebooks.com/9789041126580/Double-Taxation-Tax-Treaties-Treaty-9041126589/plp
AbeBooks.com: Double Taxation, Tax Treaties, Treaty Shopping and the European Community (Eucotax Series on European Taxation, 15) (9789041126580) by HJI ...
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84 Rhoades & Langer, U.S. International Taxation and Tax Treaties
https://store.lexisnexis.com/products/rhoades-langer-us-international-taxation-and-tax-treaties-skuusSku10561
The recognized text on all aspects of U.S. taxation of Americans doing business abroad and foreigners ... Chapter 54 Limitations on Treaty Shopping
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85 New Zealand's Approach to Treaty Shopping - NZLII
http://www.nzlii.org/nz/journals/AukULawRw/2007/4.pdf
(2005) Commentary on Article I, [9.4] ["Model Tax Convention"]. Page 2. Auckland University Law Review. II DOUBLE TAX AGREEMENTS. Double Taxation.
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86 What Impact Will Brexit Have on Derivative Benefits Test ...
https://www.gibsondunn.com/what-impact-will-brexit-have-on-derivative-benefits-test-under-us-double-tax-treaties/
The limitation on benefits (LOB) article in U.S. tax treaties is intended to prevent “treaty shopping,” whereby residents from third ...
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87 Court Rejects Taxpayer's Claim for US-Swiss Treaty Coverage
https://www.taxcontroversy360.com/2017/08/court-rejects-taxpayers-claim-for-us-swiss-treaty-coverage/
The taxpayer alleged treaty shopping was the legal standard the IRS is required to apply when implementing Article 22(6), meaning all entities ...
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88 Tax treaties: Why the Indonesian government keeps losing in ...
https://www.ictd.ac/blog/tax-treaties-indonesia-government-losing-court/
The treaty states that a company can only take advantage of the reduced withholding taxes on dividends, royalties and interest if the company is ...
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89 Double Taxation, Tax Treaties, Treaty-Shopping and the ...
https://library.law.yale.edu/research/guides/resources/double-taxation-tax-treaties-treaty-shopping-and-european-community
Double T axation, T ax T reaties, T reaty-Shopping and the European Community. April 21, 2013 - 4:03pm by Jason Eiseman. Catalog Link:.
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90 Tax treaties of G-24 Countries: Analysis Using a New Dataset
https://www.g24.org/wp-content/uploads/2021/06/G24-treaties-WP_Final.pdf
'treaty shopping'. A new dataset of developing countries' tax treaties, developed with support from the G-24, allows for comparisons of the ...
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91 OECD releases Action 6 peer review on tax treaty shopping
https://www.accountancydaily.co/oecd-releases-action-6-peer-review-tax-treaty-shopping
Each jurisdiction will have to submit details of all existing comprehensive tax treaties on income taxes in force and in effect at 30 June 2018. They will also ...
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92 Laws passed to end mulitnational tax 'treaty shopping' - AFR
https://www.afr.com/politics/laws-passed-to-end-mulitnational-tax-treaty-shopping-20180820-h146wl
Australia will join 70 other countries as part of a new OECD tax convention after legislation passed Parliament.
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93 Australia: Tax Insight: ATO's Taxpayer Alert On Treaty Shopping
https://www.mondaq.com/australia/withholding-tax/1215208/tax-insight-ato39s-taxpayer-alert-on-treaty-shopping
Treaty shopping · terminating an existing licensing arrangement and replacing it with an arrangement with similar terms but between different ...
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