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

Defences

Commentary – Schwarz on Tax Treaties ¶25-550

Exclusion of tax-favoured entities

Commentary – Schwarz on Tax Treaties ¶25-450

Generally

Commentary – Schwarz on Tax Treaties ¶11-250 ; Schwarz on Tax Treaties ¶11-300

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

Procedural rules

Commentary – Schwarz on Tax Treaties ¶25-800

Purpose provisions

Commentary – Schwarz on Tax Treaties ¶25-600

Subject-to-tax approach

Commentary – Schwarz on Tax Treaties ¶25-400

Beneficial ownership

Commentary – Schwarz on Tax Treaties ¶25-300

Limitation on benefits

Commentary – Schwarz on Tax Treaties ¶11-250 ; Schwarz on Tax Treaties ¶14-150

Outline

Commentary – Schwarz on Tax Treaties ¶25-150