This study considers how tax authorities attempt to strike down international tax avoidance structures, in particular those involving the use of conduit and bas

Analysis of notion, roots und measures of treaty abuse The OECD initiative on Base Erosion and Profit Shifting has put the issue of treaty abuse and the means t

In international tax law, the term ‘beneficial ownership’ refers to which parties involved in a cross-border transaction are entitled to tax treaty benefits

Should the income of a corporate group be taxed differently solely because the traditional structure of the income tax system considers each company individuall

This authoritative book provides a structural, global view of evolving judicial and doctrinal trends in the understanding of beneficial ownership in internation