Taxation of bilateral investments : tax treaties after BEPS / Carlo Garbarino (Angelo Sraffa Department of Legal Studies, Bocconi University, Italy and Senior Fellow of the Melbourne Law School, 2018-19).

Northampton, MA : Edward Edgar Pub., 2019.

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9781788976893 (e-book)

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eep9781788976893

The OECD's guidance on combatting tax avoidance strategies associated with Base Erosion and Profit Sharing (BEPS) methods is complex and accompanied by a wealth of literature. This book is the first to provide a concise and accessible overview of counter BEPS measures in the OECD Model and Commentary, allowing readers to gain a practical understanding of how the measures can impact the taxation of bilateral investments protected by tax treaties. Key features include: ; Practical analysis of tax treaties from the perspective of the country which is the destination of foreign investment ; Chapters that explore specific aspects of doing business in a destination country which employs the measures set out in the OECD Model and Commentary ; Explanation of how BEPS treaty rules affect a range of corporate tax strategies including: permanent establishment, use of corporate vehicles and intra-group transactions ; Information on administrative matters associated with BEPS, focusing on dispute settlement and cooperation in enforcement. Providing a succinct and practical approach to the topic, this book will be an insightful resource for those practising in the field of international taxation as well as corporate in-house counsel. Researchers and students seeking clear information on BEPS and its real world application affecting tax treaties will also benefit from this concise guide.

Includes index.

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