Anti-Avoidance Rules in Recent Tax Treaties

Journal
International; OECD
Bulletin for International Taxation 2012 (Volume 66), No. 6
The author, in this article, examines how countries have used the anti-avoidance provisions contained in the OECD Model (2010) in recent tax treaties to deal with inappropriate structures involving passive income, such as dividends, interest, royalties and capital gains.