The limitation on benefits [LOB] provision in BEPS Action 6/MLI : ineffective overreaction of mind-numbing complexity - part 2

Resource Information

The work The limitation on benefits [LOB] provision in BEPS Action 6/MLI : ineffective overreaction of mind-numbing complexity - part 2 represents a distinct intellectual or artistic creation found in International Bureau of Fiscal Documentation. This resource is a combination of several types including: Work, Language Material, Continuing Resources.

Label

The limitation on benefits [LOB] provision in BEPS Action 6/MLI : ineffective overreaction of mind-numbing complexity - part 2

Creator

• Kuźniacki, B

Subject

• BEPS Project (OECD)
• LoB
• MLI
• treaty abuse

Language

eng

Summary

This is the second of a two-part article addressing the usefulness of the limitation on benefits (LoB) provision in base erosion and profit shifting (BEPS) Action 6 and the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) in prevention of abusive treaty shopping - the most prevalent and typical form of treaty abuse. The study concludes that the MLI LoB rule is an ineffective overreaction of "mind-numbing complexity" which, despite its great potential to reflect the nature of tax treaties and treaty shopping, seems to be a lost opportunity to address that most prevalent form of treaty abuse in a targeted, effective manner

Citation source

In: Intertax. - Alphen aan den Rijn. - Vol. 46 (2018), no. 2 ; p. 124-139

Geographic coverage

International

Language note

English