Anti-abuse measures

Beneficial ownership

Bona fide provisions, use of

Channel approach

Conduit companies

Directive abuse

Exclusion of tax-favoured entities

Generally

Judicial approaches

Look-through rules

Other approaches

Procedural rules

Proportionality

Purpose provisions

Subject-to-tax approach

Tax base erosion

US Treaty limitation on benefits

Directive shopping

General anti-avoidance rule

Intermediaries

Meaning of tax avoidance

OECD Model, changes to commentary

Ramsay doctrine

Royalties

Tax base erosion

Thin capitalisation

Treaty interaction with domestic legislation

Treaty shopping