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Taxation of Bilateral Investments
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Taxation of Bilateral Investments

Tax Treaties after BEPS

9781788976886 Edward Elgar Publishing
Carlo Garbarino, Angelo Sraffa Department of Legal Studies, Bocconi University, Italy and Senior Fellow of the Melbourne Law School, 2018-19
Publication Date: 2019 ISBN: 978 1 78897 688 6 Extent: 240 pp
The OECD’s guidance on combatting tax avoidance strategies associated with Base Erosion and Profit Sharing (BEPS) methods is complex and accompanied by a wealth of literature. This book is the first to provide a concise and accessible overview of counter BEPS measures in the OECD Model and Commentary, allowing readers to gain a practical understanding of how the measures can impact the taxation of bilateral investments protected by tax treaties.

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Critical Acclaim
Contents
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The OECD’s guidance on combatting tax avoidance strategies associated with Base Erosion and Profit Sharing (BEPS) methods is complex and accompanied by a wealth of literature. This book is the first to provide a concise and accessible overview of counter BEPS measures in the OECD Model and Commentary, allowing readers to gain a practical understanding of how the measures can impact the taxation of bilateral investments protected by tax treaties.

Key features include:
• Practical analysis of tax treaties from the perspective of the country which is the destination of foreign investment

• Chapters that explore specific aspects of doing business in a destination country which employs the measures set out in the OECD Model and Commentary

• Explanation of how BEPS treaty rules affect a range of corporate tax strategies including: permanent establishment, use of corporate vehicles and intra-group transactions

• Information on administrative matters associated with BEPS, focusing on dispute settlement and cooperation in enforcement.

Providing a succinct and practical approach to the topic, this book will be an insightful resource for those practising in the field of international taxation as well as corporate in-house counsel. Researchers and students seeking clear information on BEPS and its real world application affecting tax treaties will also benefit from this concise guide.
Critical Acclaim
‘Garbarino offers his deep knowledge in international tax systems to explain the new international tax planning thresholds. Changes of tax treaty standards derived from the BEPS Project especially, those reflected in the 2017 OECD Model/Commentary offer a basis for insightful guidance from the perspective of the country of destination of the investment. Garbarino analyses the test of the permanent establishment and treaty entitlement and encompasses rules related to corporate vehicles. Investors and their tax advisors, public authorities (including tax judges) and academics will find excellent guidance for their activities in this new international tax scenario.’
– Luís Eduardo Schoueri, University of São Paulo and the Brazilian Tax Law Institute, Brazil
Contents
Contents: 1. Doing Business Through a Permanent Establishment (PE) 2. Entitlement to Tax Treaties 3. Doing Business Through Corporate Vehicles 4. Dispute Settlement and Enforcement Index

This title is available for institutional purchase via Elgaronline.

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eISBN: 978 1 78897 689 3
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