The Economic Allocation of Income and the Disregarding of Narrowly Held Entities Following the OECD/G20 Base Erosion and Profit Shifting Project

Abstract

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The silent development of Exchange of Information rules running in parallel to international tax development may have been overlooked and underestimated. The use of economic or colloquial concepts to exchange information on subjects related to a treaty case may push allocation of income to their economic or substance approaches and induce to an increase of disregard of arrangements and legal persons