The need for LOB clauses in DTCs

Paolo Arginelli; Francesco Avella

The need for LOB clauses in DTCs

Paolo Arginelli, Francesco Avella

Università Cattolica del Sacro Cuore

Research output: Chapter in Book/Report/Conference proceeding › Chapter

Abstract

[Autom. eng. transl.] The paper discusses the advantages deriving from the inclusion of LOB clauses within bilateral conventions to avoid double taxation and analyzes whether, from the Italian perspective, such inclusion is necessary in order to avoid those forms of abuse of the conventions commonly referred to as “treaty shopping"

Original language	English
Title of host publication	Limitation on Benefit Clauses in International Taxation Law
Editors	M. Graggi
Pages	20-29
Number of pages	10
Publication status	Published - 2014

Keywords

Tax Treaty
limitation on benefits clauses

Cite this

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AB - [Autom. eng. transl.] The paper discusses the advantages deriving from the inclusion of LOB clauses within bilateral conventions to avoid double taxation and analyzes whether, from the Italian perspective, such inclusion is necessary in order to avoid those forms of abuse of the conventions commonly referred to as “treaty shopping"

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KW - limitation on benefits clauses

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BT - Limitation on Benefit Clauses in International Taxation Law

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ER -

The need for LOB clauses in DTCs

Abstract

Keywords

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