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Treaty shopping defence provisions: Part 2

Published on 01 Feb 11 by "THE TAX SPECIALIST" JOURNAL ARTICLE

This two-part article focuses on the effectiveness of treaty shopping defence provisions included in double tax agreements and domestic law provisions. In the October 2010 issue of this journal, Part 1 of the article considered the various treaty shopping defence provisions that the Commissioner of Taxation has recourse to in relation to an inbound Australian investment structure. Part 2 considers the application of treaty shopping defence provisions and doctrines to an outbound Australian investment structure, reviewing recent jurisprudence and government policy of foreign jurisdictions.

Author profile:

Tim Loh CTA
Tim is a Lawyer at Blake Dawson. Current at 01 February 2011 Click here to expand/collapse more articles by Tim LOH.
 
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