Description
Court decisions influence the understanding of GAAR and in particular the PPT included in some DTCs and recommended by Model Tax Conventions already since 2017. I presented the recent case on PPT decided by a British Court and together with Christian Anguita analyzed the different situations in which the GAAR apply with case law exemplifying each situation. The lecture also dived into the different elements of GAARs as approached by judges.| Period | 13 Sept 2023 |
|---|---|
| Event title | Curso de Postgrado: Profundización en Derecho Internacional Tributario: Postgraduate Course: International Taxation Follow Up Professional Level |
| Event type | Course |
| Location | Brussels, BelgiumShow on map |
| Degree of Recognition | International |
Documents & Links
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Activities
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Database of cases on abuse in International Tax, CIAT
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Chronic of a death foretold. The Principal Purpose Test in Tax Treaties
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Special Anti-Abuse Provisions, case law
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Fundamentals of International Taxation, emphasis on Tax Treaty Law (Fundamentos de la Tributación Internacional, énfasis en Convenios)
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Limitations to business freedom and tax competition (Limitaciones a la libertad contractual y de negocios y competencia fiscal)
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