: Desiree Auer, Christina Dimitropoulou
: Access to Treaty Benefits Series on International Tax Law, Volume 125
: Linde Verlag Wien Gesellschaft m.b.H.
: 9783709411612
: Schriftenreihe zum Internationalen Steuerrecht
: 1
: CHF 72.00
:
: Internationales Recht, Ausländisches Recht
: English
: 496
: DRM
: PC/MAC/eReader/Tablet
: ePUB

A rigorous analysis of various aspects related to treaty access

Tax treaty access is an ongoing challenge for both taxpayers and tax authorities. This volume provides a rigorous analysis of various aspects related to treaty access. Schematically, the volume is divided into four parts. The first part deals with general interpretative issues and principles; the second and third parts cover a wide range of sub-aspects relating to the subjective and objective scope of tax treaties and the recent challenges posed to tax treaty access, while the fourth part focuses on the knotty issues of treaty shopping and abuse.


The structure of the volume reflects the necessity to approach access to treaty benefits in a holistic way and view the recent trends through a wide lens. All chapters contain a complete examination of the relevant topics, starting from a historical perspective and continuing with tax treaty law principles and tax practice analysis. Where appropriate, a domestic law and domestic courts’ jurisprudence perspective was added as well as a comparative analysis of several jurisdictions thus complementing the examination of each topic. Finally, special attention is given to treaty abuse and the new GAAR introduced in the 2017 OECD Model together with its interrelation with other treaty and domestic anti-abuse provisions and the impact of these provisions on tax treaty access and tax policy in general.

IXList of Authors


Tomás Álvarez Palacios

Tomás Álvarez Palacios was born in Santiago de Chile in 1986. In 2011, he completed his B.A. in Law at the Pontificia Universidad Católica de Chile. He also holds an LL.M. in Tax Law from the Universidad Adolfo Ibáñez, Chile (2015). From 2012 to 2015 he worked at two law offices in Santiago de Chile: Boffil Mir& Álvarez Jana Attorneys and Porzio, Ríos, García Attorneys. After that, he joined Mazars Chile as a Tax Attorney and was promoted to Tax& Legal Manager in 2017. He joined KPMG Chile in 2018 as a Supervisor Attorney in the International Corporate Tax Department.

Eva Bernichon

Eva Bernichon graduated in 2020 with a Master‘s degree in Corporate Taxation and a Magistère in Business Law, Taxation and Accounting from the University of Aix-Marseille in France. After one year’s practice experience as a tax assistant in the financial departme