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 ...
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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.
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Add this copy of IFA: How Domestic Anti-Avoidance Rules Affect Double to cart. $80.52, new condition, Sold by Ingram Customer Returns Center rated 5.0 out of 5 stars, ships from NV, USA, published 1995 by Kluwer Law International.
Add this copy of IFA: How Domestic Anti-Avoidance Rules Affect Double to cart. $84.14, new condition, Sold by Ria Christie Books rated 5.0 out of 5 stars, ships from Uxbridge, MIDDLESEX, UNITED KINGDOM, published 1995 by Kluwer Law International.
