| Ifa: How Domestic Anti-Avoidance Rules Affect Double Taxation Conventions: How Domestic Anti-Avoidance Rules Affect Double Taxation Conventions Contributor(s): International Fiscal Association (Ifa) (Author) |
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ISBN: 9041100709 ISBN-13: 9789041100702 Publisher: Kluwer Law International OUR PRICE: $74.25 Product Type: Paperback - Other Formats Published: September 1995 |
| Additional Information |
| BISAC Categories: - Law | International - Law | Taxation - Business & Economics | Public Finance |
| Dewey: 341.484 |
| LCCN: 95017921 |
| Series: Ifa Congress Series Set |
| Physical Information: 0.13" H x 6.14" W x 9.21" (0.22 lbs) 64 pages |
| Descriptions, Reviews, Etc. |
| Publisher Description: 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. |