Double Taxation Treaties (“DTT“) are treaties between two or more countries to avoid international double taxation of income and property of individuals or legal entities. The main purpose of DTT is to divide the right taxation between the involved countries, to avoid differences in taxation and to ensure taxpayers’ equal rights and security. International tax planning has become a serious concern and companies started to shift their income to low-taxed jurisdictions. Therefore, states with a higher taxation fear for their tax revenues. That is the reason why the prevention of abusive use of tax treaty benefits became a central aspect in the tax treaty policy of most industrialized countries.
Table of Content
Table of Content
Abbreviations
1. Introduction
2. Purpose and basic operation of the LOB
3. Structure of the Article
3.1 Individuals and Contracting States
3.2 Publicly-Traded-Corporations
3.3 Tax-Exempt Organizations and Pension Funds
3.4 Other legal entities
4. National anti-abuse rules
5. Summary
Register of Literature
Register of legal sources
Register of jurisdictions
- Quote paper
- Anonymous,, 2020, US Tax law. The Limitation-on-Benefits-Clause and US national anti abuse rules, Munich, GRIN Verlag, https://www.grin.com/document/955813
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