Domestic anti avoidance measures remain effective despite treaty provisions, allowing states to enforce anti tax evasion laws domestically. Article 28A provides that the Agreement shall not prevent a Contracting State from applying its domestic law and measures concerning the prevention of tax ... Summary
Domestic anti avoidance measures remain effective despite treaty provisions, allowing states to enforce anti tax evasion laws domestically.
Article 28A provides that the Agreement shall not prevent a Contracting State from applying its domestic law and measures concerning the prevention of tax avoidance or tax evasion; it operates as a non derogation clause preserving domestic anti avoidance and anti evasion enforcement notwithstanding treaty provisions.
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