Double taxation agreements barred from creating non taxation or treaty shopping advantages, protecting against indirect third country benefits. The amendment conditions the adoption and implementation of inter-association agreements for the avoidance of double taxation on the requirement that such agreements not create opportunities for non-taxation or reduced taxation through tax evasion or avoidance, explicitly encompassing arrangements constituting treaty-shopping aimed at obtaining treaty reliefs for the indirect benefit of residents of other countries or territories.
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Provisions expressly mentioned in the judgment/order text.
Double taxation agreements barred from creating non taxation or treaty shopping advantages, protecting against indirect third country benefits.
The amendment conditions the adoption and implementation of inter-association agreements for the avoidance of double taxation on the requirement that such agreements not create opportunities for non-taxation or reduced taxation through tax evasion or avoidance, explicitly encompassing arrangements constituting treaty-shopping aimed at obtaining treaty reliefs for the indirect benefit of residents of other countries or territories.
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