The Economic Allocation of Income and the Disregarding of Narrowly Held Entities Following the OECD/G20 Base Erosion and Profit Shifting Project
Abstract
. 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
The Economic Allocation of Income and the Disregarding of Narrowly Held Entities Following the OECD/G20 Base Erosion and Profit Shifting Project
Tipo de Actividad
Artículos en revistasISSN
1819-5490Palabras Clave
.Exchange of Information, BEPS, Allocation of Income, Tax Treaties, Disregard of entities, Controlled-Foreign-Corporations, CFC