Avoidance
Anti-abuse measures
Beneficial ownership
Commentary –
Schwarz on Tax Treaties ¶25-300
Bona fide provisions, use of
Commentary –
Schwarz on Tax Treaties ¶25-550
;
Schwarz on Tax Treaties ¶25-750
Channel approach
Commentary –
Schwarz on Tax Treaties ¶25-500
Conduit companies
Commentary –
Schwarz on Tax Treaties ¶25-300
Directive abuse
Commentary –
Schwarz on Tax Treaties ¶22-450
Exclusion of tax-favoured entities
Commentary –
Schwarz on Tax Treaties ¶25-450
Generally
Commentary –
Schwarz on Tax Treaties ¶11-350
;
Schwarz on Tax Treaties ¶25-250
;
Schwarz on Tax Treaties ¶25-350
Judicial approaches
Commentary –
Schwarz on Tax Treaties ¶25-850
Look-through rules
Commentary –
Schwarz on Tax Treaties ¶25-650
;
Schwarz on Tax Treaties ¶25-700
Other approaches
Commentary –
Schwarz on Tax Treaties ¶25-750
Procedural rules
Commentary –
Schwarz on Tax Treaties ¶11-350
;
Schwarz on Tax Treaties ¶25-800
Proportionality
Commentary –
Schwarz on Tax Treaties ¶11-350
Purpose provisions
Commentary –
Schwarz on Tax Treaties ¶25-600
Subject-to-tax approach
Commentary –
Schwarz on Tax Treaties ¶25-400
Tax base erosion
Commentary –
Schwarz on Tax Treaties ¶11-350
US Treaty limitation on benefits
Commentary –
Schwarz on Tax Treaties ¶25-700
Directive shopping
Commentary –
Schwarz on Tax Treaties ¶22-450
General anti-avoidance rule
Commentary –
Schwarz on Tax Treaties ¶25-200
Intermediaries
Commentary –
Schwarz on Tax Treaties ¶25-050
Meaning of tax avoidance
Commentary –
Schwarz on Tax Treaties ¶11-350
;
Schwarz on Tax Treaties ¶25-050
OECD Model, changes to commentary
Commentary –
Schwarz on Tax Treaties ¶25-200
Ramsay doctrine
Commentary –
Schwarz on Tax Treaties ¶25-050
Royalties
Commentary –
Schwarz on Tax Treaties ¶18-200
Tax base erosion
Commentary –
Schwarz on Tax Treaties ¶11-350
Thin capitalisation
Commentary –
Schwarz on Tax Treaties ¶11-350
Treaty interaction with domestic legislation
Commentary –
Schwarz on Tax Treaties ¶25-100
Treaty shopping
– see Treaty shopping