LEADER 02363oam 2200409 450 001 9910826927303321 005 20231205162407.0 010 $a90-8722-639-X 010 $a90-8722-640-3 035 $a(CKB)4100000011509204 035 $a(MiAaPQ)EBC6372020 035 $a(EXLCZ)994100000011509204 100 $a20210227d2020 uy 0 101 0 $aeng 135 $aurcnu|||||||| 181 $ctxt$2rdacontent 182 $cc$2rdamedia 183 $acr$2rdacarrier 200 14$aThe anti-abuse rule for permanent establishments situated in third states $ea legal analysis of article 29(8) OECD model /$fJean-Philippe Van West 210 1$aAmsterdam :$cIBFD,$d[2020] 210 4$dİ2020 215 $a1 online resource (341 pages) 225 1 $aEuropean and international tax law and policy series ;$vVolume 16 311 0 $a90-8722-638-1 330 $aWithin the framework of its Base Erosion and Profit Shifting (BEPS) Project, the OECD has developed a new specific anti-abuse rule to address certain types of triangular situations leading to low taxation, resulting in the inclusion of article 10, entitled "Anti-abuse Rule for Permanent Establishments Situated in Third States", in the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (2016) and article 29(8) of the OECD Model (2017). As a consequence, an increasing number of tax treaties include a specific anti-abuse rule based on article 29(8) of the OECD Model, and since only four OECD member countries have made a reservation to this article, it is expected that this trend will continue. Despite its growing importance, the provision has received little attention in the tax literature compared to other BEPS measures. This book aims to fill this research gap and provides a critical in-depth legal analysis of article 29(8) of the OECD Model and its functioning within the convention. 410 0$aEuropean and international tax law and policy series ;$vVolume 16. 606 $aTaxation 615 0$aTaxation. 676 $a336.2 700 $aWest$b Jean-Philippe Van$01622243 801 0$bMiAaPQ 801 1$bMiAaPQ 801 2$bMiAaPQ 906 $aBOOK 912 $a9910826927303321 996 $aThe anti-abuse rule for permanent establishments situated in third states$93955998 997 $aUNINA