At head of title on cover: WU Institute for Austrian and International Tax Law. Includes bibliographical references.
Contents:
The relevance of the preamble for treaty entitlement / Clare (Xue) Peng, Joseph Schuch -- The application of the principal purpose test under tax treaties / Svitlana Buriak -- Limitation on benefits clauses : limiting the entitlement to treaty benefits / Lisa Ramharter, Rita Szudoczky -- The beneficial ownership test / Florian Navisotschnigg -- Resident persons according to article 1(1) of the OECD Model / Claus Staringer, Desiree Auer -- Dual residence and treaty entitlement of individuals / Karol Dziwiński -- Dual residence for non-individuals / Peter Bräumann -- Tax treaty entitlement and hybrid entities : article 1(2) and article 1(3) of the OECD Model (2017) / Jean-Philippe Van West -- Entitlement to protection against discriminatory taxation / Pasquale Pistone, Clement Migai -- Personal scope of the mutual agreement procedure and arbitration provisions, and the mutual assistance provisions / Sriram Govind.
Summary:
"The entitlement to tax treaty benefits is of pivotal importance for taxpayers in order to obtain treaty benefits. However, the application and interpretation of the respective tax treaty provisions are not always straightforward and may often raise various questions. This is all the more true now that the OECD has introduced a number of new provisions regarding the entitlement to tax treaties into its Model Convention as part of the BEPS Project."--Page four of cover.
Series:
European and International Tax Law and Policy Series, 2451-8360 ; v. 11
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