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

See all articles by Leopoldo Parada

Leopoldo Parada

University of Leeds School of Law

Date Written: January 21, 2021

Abstract

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

Parada, Leopoldo, Tax Treaty Entitlement and Fiscally Transparent Entities: Improvements or Unnecessary Complications? (January 21, 2021). J. Wheeler (ed), The Aftermath of BEPS (IBFD, 2020), Available at SSRN: https://ssrn.com/abstract=3770814 or http://dx.doi.org/10.2139/ssrn.3770814

Leopoldo Parada (Contact Author)

University of Leeds School of Law ( email )

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