Why this book?
The entitlement to tax treaty benefits is of pivotal importance for taxpayers in order to obtain treaty benefits. However, the application and interpretation of the respective tax treaty provisions are not always straightforward and may often raise various questions. This is all the more true now that the OECD has introduced a number of new provisions regarding the entitlement to tax treaties into its Model Convention as part of the BEPS Project.
This book analyses several crucial areas concerning the entitlement to tax treaties. The topics covered include:
The application of the principal purpose test, limitation on benefits clauses and the beneficial ownership test
The relevance of the term “person” within the OECD Model
Dual residence for individuals and non-individuals
The tax treaty entitlement of hybrid entities
The entitlement to protection against discriminatory taxation
The personal scope of the mutual agreement procedure and arbitration provisions, and the mutual assistance provisions
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