Domestic anti-abuse rules and double taxation treaties : a Spanish perspective - part II

Journal
Martín Jiménez, A.J.
Bulletin for International Taxation 2002 (Volume 56), No. 12
PriceUSD 45

In this second part two problems are considered that are connected with the interaction of general anti-abuse clauses in domestic law with specific anti-abuse clauses in tax treaties and the relationship between specific anti-abuse clauses in domestic law (e.g. thin capitalization and CFC rules) and in tax treaties.