The Resource Treaty entitlement of investment funds in light of BEPS Actions 2 and 6

Treaty entitlement of investment funds in light of BEPS Actions 2 and 6

Label
Treaty entitlement of investment funds in light of BEPS Actions 2 and 6
Title
Treaty entitlement of investment funds in light of BEPS Actions 2 and 6
Creator
Subject
Language
eng
Summary
Both the limitation-on-benefits clause and the principal purpose test proposed by the OECD in its current base erosion and profit shifting (BEPS) initiative aim at countering treaty shopping. A closer look reveals that these rules could have considerable effect on the tax treaty entitlement of investment funds. In this article the authors shed light on the provisions proposed so far, their interplay with the proposed article 1(2) of the OECD Model and their effects on the treatment of investment funds under international tax law
Citation source
In: Derivatives and financial instruments. - Amsterdam. - Vol. 18 (2016),
http://library.link/vocab/creatorName
  • Blum, D.W
  • Pinetz, E
Geographic coverage
International
Language note
English
http://library.link/vocab/subjectName
  • treaty shopping
  • treaty abuse
  • LoB
  • principal purpose test
  • BEPS
  • investment fund
Label
Treaty entitlement of investment funds in light of BEPS Actions 2 and 6
Instantiates
Publication
Label
Treaty entitlement of investment funds in light of BEPS Actions 2 and 6
Publication

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