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Book

Limits to Tax Planning



This collection of master theses analyses various measures and aspects of tax planning, such as corporate residence, the set-up of partnerships and holding companies, transfer pricing, and the shopping into tax treaties, specific tax treaty rules and EU Directives. The main focus of this book lies on countermeasures to tax planning: CFC rules, thin cap rules, interest barrier rules and tax collection at withholding are examined as examples for national measures. The tax treaty law measures presented in this book include mutual assistance, limitation on benefits, subject-to-tax and activity clauses, the beneficial ownership concept, as well as anti-abuse rules of specific allocation rules. Within the EU, anti-tax planning measures must respect Union law, which includes the fundamental freedoms, as well as provisions of secondary EU law, such as the Savings, Merger, Parent-Subsidiary and Interest and Royalty Directive, but also the harmonized area of indirect taxes and the CCCTB.


Detail Information

Call Number
07 LIM kar
Publisher Linde Verlag : Wien.,
Collation
624p.; 22.5cm
Language
English
Classification
07 LIM kar
ISBN/ISSN
978-3-7073-2408-2
Edition
Series on International Tax Law
Subject(s)