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

Journal
Bulletin for International Taxation 2002 (Volume 56), No. 12
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.