The Resource What makes a Dutch company Dutch? The evolution of US limitation-on-benefits provisions

What makes a Dutch company Dutch? The evolution of US limitation-on-benefits provisions

Label
What makes a Dutch company Dutch? The evolution of US limitation-on-benefits provisions
Title
What makes a Dutch company Dutch? The evolution of US limitation-on-benefits provisions
Creator
Subject
Language
eng
Summary
A US-style limitation-on-benefits (LOB) test prevents most common forms of treaty shopping, at least when it is combined with anti-abuse rules aimed at specific transactions. However, it is not at all clear that the United States has significantly increased the amount of withholding taxes that it collects. Instead, it measures the success of the expanded LOB rules by the extent to which it achieves its goal of reducing withholding rates in treaties with important trading partners (such as Japan and Canada) or widens its treaty network to other countries that may be important sources of investment capital (such as Israel). The achievement of these goals has required substantial resources: having even one treaty without a LOB provision is almost as bad as having no LOB provisions in any treaty. Accordingly, a country should be very clear about its goals, and realistic about the difficulty of negotiating LOB provisions, before embarking on an anti-treaty-shopping strategy based primarily on the introduction of a LOB provision into its tax treaties
Citation source
In: Canadian tax journal = Revue fiscale canadienne. - Toronto. - Vol. 62 (2014),
http://library.link/vocab/creatorName
Brown, P.A
Language note
English
http://library.link/vocab/subjectName
  • LoB
  • treaty shopping
  • withholding tax
  • tax treaty
  • nexus
  • place of effective management
Label
What makes a Dutch company Dutch? The evolution of US limitation-on-benefits provisions
Instantiates
Publication
Label
What makes a Dutch company Dutch? The evolution of US limitation-on-benefits provisions
Publication

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