The Interaction of Domestic Anti-Avoidance Rules with Tax Treaties in the Post-BEPS and Digitalized World

Journal
Chand, V.; Elliffe, C.
International; OECD
Bulletin for International Taxation 2020 (Volume 74), No. 4/5
Format/Price
JournalUSD 45

In its analysis, this article distinguishes between domestic anti-avoidance rules that counteract treaty abuse and those that thwart abuse of domestic law. The authors conclude that conflicts could arise with tax treaties. States should employ a provision that authorizes the application of these rules to prevent this situation arising.