The need for LOB clauses in DTCs

Paolo Arginelli, Francesco Avella

Research output: Chapter in Book/Report/Conference proceedingChapter


[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 languageEnglish
Title of host publicationLimitation on Benefit Clauses in International Taxation Law
EditorsM. Graggi
Number of pages10
Publication statusPublished - 2014


  • Tax Treaty
  • limitation on benefits clauses


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