Treaty shopping
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