Principal purpose test in Brazilian tax treaties

Bilateral Tax Treaties and GDP Comovement

Using a 30-year panel of quarterly GDP fluctuations from of a broad set of countries, we demonstrate that the signing of a bilateral tax treaty increases the comovement of treaty partners’ business cycles by 1/2 a standard deviation. This effect of fiscal policy is as large as the effect of trade linkages on comovement, and stronger than the effects of several other common financial and investm...

Double Tax Treaties and Their Interpretation

Clarifying the Meaning of ‘Beneficial Owner’ in Tax Treaties

and general language. Also, the discussion drafts do not clarify the context, object, and purpose to be considered in the interpretation of beneficial owner. Regarding the context, the drafts only explain that ‘‘the term ‘beneficial owner’ was added to address potential difficulties arising from the use of the words ‘paid to . . . a resident’ in paragraph 1,’’19 but they leave unspoken exactly ...

Gradualism in Tax Treaties with Irreversible Foreign Direct Investment

Bilateral international tax treaties govern the host country taxation for the vast majority of the world’s foreign direct investment (FDI). Of particular interest is the fact that the tax rates used under these treaties are gradually falling although the treaties themselves do not specify any such reductions. Since there is no outside governing agency to redress treaty violations, such reductio...

Algorithms for the Network Analysis of Bilateral Tax Treaties

In this thesis we conduct a network analysis of bilateral tax treaties. We are given tax data of 108 countries. Companies often send money from country to country via indirect routes, because then the tax that must be paid might be lower. In the thesis we will study the most important of these ‘tax’ routes. Questions that we will answer are, for example: 1. Which countries are the most importan...