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Series Editor’s Preface
5
Editors’ Preface
7
List of Authors
9
Meaning and Concept of “Treaty Abuse” in DTA Law
16
Historical Development of the OECD’s Workon Treaty Abuse
38
Preventing Treaty Abuse: The United Nations’ Perspective
60
DTCs and Double Non-Taxation
84
Policy Considerations when Concluding a Tax Treaty in a Post-BEPS World
102
Tax Treaty Entitlement in Triangular Cases
122
Tie-Breaker for Dual Resident Companies
142
Limitation on Benefits Clauses – Function, Purpose and History
161
Limitation on Benefits: Qualified Persons
198
LoB – Article X (3) of the OECD MC: Active Conduct of a Business
220
Limitation on Benefits: Derivative Benefitsand Discretionary Relief
244
Limitation on Benefits and (non-)CollectiveInvestment Vehicles
266
Limitation on Benefits and EU Law
284
Limitation on Benefits: Comparison between the US LOB and the OECD LOB proposedunder Action 6
306
The Principal Purpose Test: Functioning, Elements and Legal Relevance
324
The Principal Purpose Test: Comparison with EU-GAAR Initiatives
339
OECD Minimum Standard: Comparing LOB and PPT
361
Treaty Abuse and Permanent Establishments: Proposed Changes to Article 5(3) and (4) of the OECD MC
382
Treaty Abuse and Permanent Establishments: Proposed Changes to Articles 5(5) and 5(6) of the OECD MC
408
Anti-Abuse Clause for Permanent Establishments in Third Countries
432
Treaty Abuse and Passive Income: Granting of Treaty Benefits in the Case of “Special Tax Regimes”
452
Treaty Abuse and Passive Income: Holding Period for Intercompany Dividends and Modifications to Article 13 Para. 4 OECD MC
473
Treaty Abuse and Beneficial Ownership: Latest OECD Developments
508
Relationship between Domestic GAARs and Tax Treaty Law
526
The Relationship Between Domestic Specific Anti-Avoidance Rules and Tax Treaty Law
543
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