Tax Treaty Entitlement and Fiscally Transparent Entities: Improvements or Unnecessary Complications?
J. Wheeler (ed), The Aftermath of BEPS (IBFD, 2020)
31 Pages Posted: 12 Mar 2021
Date Written: January 21, 2021
This chapter analyses the recent modifications to the 2017 OECD Model Tax Convention as regards fiscally transparent entities. The ultimate aim of the Chapter is to determine how these modifications have impacted the dynamic of granting or denying tax treaty benefits and whether these changes represent an improvement or just an unnecessary complication. The time to revisit these issues could not be more appropriate.
Keywords: transparent entities; hybrid entities; OECD Model; Action 2
JEL Classification: K34
Suggested Citation: Suggested Citation