Wolters Kluwer Limitation on Benefits Clauses in Double Taxation Conventions, 2nd Edition (EUCOTAX Series on European Taxation)

Upfront planning for international structures is crucial to ensure coverage under bilateral tax treaties. However, because treaty shopping whereby a third-party national or a corporation sets up a shell company in order to minimize or eliminate income tax can potentially be facilitated by taking advantage of double taxation conventions, companies must carefully scrutinize and comply with requirements found in the limitation on benefits (LOB) clauses in tax treaties. This second edition of the only publication directly analysing the legal framework and application of LOB clauses in double taxation conventions adds detailed coverage of such major recent developments as the recent tax treaties concluded between the United States (US) and European Union (EU) Member States, the last version of the US Model Tax Convention (2016), the OECD/G20 project on Base Erosion and Profit Shifting (BEPS), and relevant new rulings handed down by the European Court of Justice.