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Limitation on Benefits Clauses in Double Taxation Conventions - 9789041123701

Un libro in lingua di Vega Borrego Felix Alberto edito da Kluwer Law Intl, 2005

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Article 22 of the 1996 Model Treaty requires most double taxation conventions entered into by the US to contain what are called "limitation on benefits clauses" which exist to prevent what is called "treaty shopping structures," in which entities pick and choose for treaties and economic relationships that benefit only themselves. Here Borrego explains the legal framework of these clauses or rules and shows how nations apply them, especially in the case of the US with the European Union member states. He covers the situation of taxation of non-residents and tax planning through double taxation conventions, the subjective scope of double taxation conventions and limitations on benefits clauses, the legal framework and application of limitations on benefit clauses, including clauses which confer the status of qualified resident and non-qualified residents entitles to receive full or partial tax treaty benefits, and the limitations on benefit clauses and European Community law. Annotation ©2006 Book News, Inc., Portland, OR (booknews.com)

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