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Rethinking Treaty-Shopping: Lessons for the European Union


Christiana Hji Panayi


Queen Mary University of London, School of Law

Reuven S. Avi-Yonah


University of Michigan Law School

January 4, 2010

U of Michigan Law & Econ, Empirical Legal Studies Center Paper No. 10-002
U of Michigan Public Law Working Paper No. 182

Abstract:     
In this paper, we reassess the traditional quasi-definitions of treaty-shopping in an attempt to delineate the contours of such practices. We examine the various theoretical arguments advanced to justify the campaign against treaty-shopping and we assess the extent to which these concerns are addressed by the OECD and the US Model.

We also consider the current trends in treaty-shopping and the anti-treaty-shopping policies under the OECD Model and the US Model. We focus on recent cases on beneficial ownership. Finally, we examine the possible implications of European Union law on the treaty-shopping debate.

Number of Pages in PDF File: 32

Keywords: tax treaties, treaty shopping, limitation on benefits

JEL Classification: H25, H26

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Date posted: January 5, 2010 ; Last revised: February 9, 2010

Suggested Citation

Hji Panayi, Christiana and Avi-Yonah, Reuven S., Rethinking Treaty-Shopping: Lessons for the European Union (January 4, 2010). U of Michigan Law & Econ, Empirical Legal Studies Center Paper No. 10-002; U of Michigan Public Law Working Paper No. 182. Available at SSRN: http://ssrn.com/abstract=1531192

Contact Information

Christiana Hji Panayi
Queen Mary University of London, School of Law ( email )
London
United Kingdom
Reuven S. Avi-Yonah (Contact Author)
University of Michigan Law School ( email )
625 South State Street
Ann Arbor, MI 48109-1215
United States
734-647-4033 (Phone)
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