Research Catalog

Details

Description

1. xxxii, 1112 p. : ill.; 24 cm.

Series statement

1. Doctoral series, 1570-7164 ; 14

Uniform title

1. Doctoral series 14.

Subject

1. Europäische Gemeinschaften
2. Tax planning > Belgium
3. Tax planning > European Economic Community countries
4. Taxation > Law and legislation > Belgium
5. Taxation > Law and legislation > European Economic Community countries
6. Investments, Foreign > Taxation > Law and legislation > Belgium
7. Investments, Foreign > Taxation > Law and legislation > European Economic Community countries
8. Double taxation > Belgium > Treaties
9. Double taxation > European Economic Community countries > Treaties

Genre/Form

1. Treaties

Contents

1. Pt. 1. The use of conduit and base companies in international tax planning: Conduit companies -- Base companies -- Illustration -- pt. 2. Prevention of abuse under Belgian domestic law: The (non-)recognition of a Belgian or foreign company or of its legal acts for Belgian income tax purposes -- Application of anti-avoidance provisions -- pt. 3. Conduit and base companies -- prevention of abuse under Belgian tax treaties: The relationship between treaties and domestic law in Belgium -- The interpretation of Belgian treaties -- Do tax treaties and Belgian tax treaties in particular include an implied anti-abuse rule of general application or an interpretation principle according to which treaty benefits should not be conferred in abusive cases? -- Application of domestic anti-avoidance rules to tax treaties: position of the OECD and analysis of case law -- Application of Belgian domestic anti-avoidance provisions to tax treaties: general observations -- Application of Belgian domestic anti-avoidance provisions to tax treaties: discussion of the provisions -- Treaty provisions preventing abuse of treaties.
2. Pt. 4. Conduit and base companies prevention of abuse under community law: Abuse of community law in matters not involving direct taxation: analysis of the ECJ case law -- Abuse of community law in relation to tax avoidance: analysis of the ECJ's case law -- The methodology of the ECJ in handling cases of abuse of community law (in particular in relation to tax avoidance) -- Requirements set by ECJ case law to national anti-avoidance measures in income tax matters -- Testing the Belgian anti-avoidance measures against the imperatives of community law.

Thesis (note)

1. Thesis (doctoral) -- Katholieke Universiteit, Leuven, 2007.

Bibliography (note)

1. Includes bibliographical references (p. 1061-1105).

Processing action (note)

1. committed to retain