In this article, the author explores and advocates the use of an artificial intelligence tax treaty assistant with regard to resolving issues and problems in respect of the principal purpose test as proposed in relation to the OECD/G20 Base Erosion and Profit Shifting initiative. As the PPT is...

The Multilateral Instrument to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) is one action by the OECD to address tax-base erosion and profit shifting (BEPS), i.e., double non-taxation or strategies consisting of artificially shifting profits to low-tax...

This paper — prepared for a symposium held at Brooklyn Law School on October 23, 2015 on Reconsidering the Tax Treaty — addresses the treaty compatibility aspect of proposals for reforming the U.S. international tax system. Finding that a reform proposal is treaty compatible obviates the...

The concept of treaty abuse, although being of great significance to the operation of international tax treaties, is by no means peculiar to this particular branch of law. A treaty abuse doctrine exists in general international law since long. As this paper argues, current work within the OECD,...

New Zealand has concluded double tax agreements with 24 countries. Double tax conventions are brought into effect by Orders in Council, a form of subordinate legislation. They are also incorporated in legislation by reference under section 294 of the New Zealand Income Tax Act 1976, which states...

In the late 1980s New Zealand signaled its intention to pass legislation to prevent resident shareholders from using controlled foreign companies to avoid tax. Controlled foreign companies all operate in a similar fashion. The regimes apply to non-resident companies that are owned or controlled...

The article argues that despite the fanfare around it, the outcome of the BEPS project is unlikely to be dramatic, at least in the short term. Beyond a period of increased legal uncertainty and aggressive enforcement by some countries, it expects little substantive change in tax treaties. The...

This paper introduces a new dataset that codes the content of 519 tax treaties signed by low- and lower-middle-income countries in Africa and Asia. Often called Double Taxation Agreements, bilateral tax treaties divide up the right to tax cross-border economic activity between their two...

This paper analyzes the differences in legal nature between the common law concept of Agency and the civil law concept of Commissionaire in light of articles 5(5) and 5(6) of the OECD Model Tax Convention. The author contradicts the idea of interpreting the civil law concept of Commissionaire is...

This article is a reply to Martin Wichmann's reply from a German perspective to John F. Avery Jones's article 'Why Can't the English ... ?', both published in the Bulletin for International Taxation of the International Bureau of Fiscal Documentation (IBFD), 2019 (Volume 73), No. 6/7. It argues...