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.
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