Published on 01 Oct 10
by "THE TAX SPECIALIST" JOURNAL ARTICLE
This two-part article considers the effectiveness of treaty shopping defence provisions. Part 1 focuses on the effectiveness of various treaty shopping defence provisions in the context of inbound Australian structures. Part 2 (to be published in the February 2011 issue of this journal) reviews recent foreign jurisprudence on the interpretation of treaty shopping defence provisions generally and highlights the interpretational differences which taxpayers should consider when structuring outbound Australian structures.
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