In this article we will discuss about:- 1. Introduction to Anti-Avoidance Doctrines 2. Common Law for Anti-Avoidance Doctrines 3. Civil Law 4. Various Countries. Introduction to Anti-Avoidance Doctrines: International tax avoidance is also affected by the interpretations of judicial bodies in various countries. The practice varies considerably. The Courts in many countries take a literal view towards statutory interpretation. Many [...]
In this article we will discuss about:- 1. Introduction to Anti-Treaty Shopping 2. Impact 3. OECD Model Treaty and Commentaries 4. Beneficial Ownership Requirement 5. Various Countries 6. Comments. Contents: Introduction to Anti-Treaty Shopping Impact of Treaty Shopping Treaty Shopping under the OECD Model Treaty and Commentaries Beneficial Ownership Requirement Anti-Treaty Shopping in Various Countries Comments on Anti-Treaty Shopping 1. [...]
The following points highlight the top two methods for the determination of arm’s length price. The methods are: 1. Traditional Transaction Methods 2. Transactional Profit Methods. 1. Traditional Transaction Methods: (a) Comparable Uncontrolled Price Method ("CUP"): The price is based on the sale or purchase from an uncontrolled party, or from an uncontrolled transaction of third parties, of identical goods [...]