The entitlement of tax treaty benefits is one of the most sensitive things for countries around the globe. The reason for it being sensitive is to ensure that benefits are granted only to persons who are genuinely entitled to them, and also to avoid any kind of tax abuse. The first step in...

This chapter analyses the recent modifications to the 2017 OECD Model Tax Convention as regards fiscally transparent entities. The ultimate aim of the Chapter is to determine how these modifications have impacted the dynamic of granting or denying tax treaty benefits and whether these changes...

Since the early 1990s the issue of fiscal transparency has attracted increasing attention from international institutions, governments, and NGO's concerned with budgets and fiscal policy reform. This Article offers a critical analysis of the meaning and purposes of fiscal transparency in light...

Constitutionalism is the idea that the powers of government can and should be limited, and that its authority flows from enforcing these limitations. In constitution making and analysis, the right or power of the government to tax seems almost superfluous. No real analysis goes into tying down...