In-depth analysis of the potential conflict between CFC legislation and tax treaties. The book also evaluates the potential conflict between the CFC legislation

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

The book provides a clear introduction to international taxation and presents its material in a global context, explaining policy, legal issues and planning poi

Compilation of 23 national reports dealing with domestic CFC provisions and the influence of tax treaties and EC law on CFC legislation and a summarising genera

Le site d'IBFD indique : "This thesis reveals a fundamental flaw in the OECD Model, namely that it pays no attention to the person who is liable to tax in respe