From the Avoidance of Double Taxation to the Avoidance of Double Non-Taxation: The Changing Objectives of Tax Treaties

P.F. Kaka

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Bulletin for International Taxation

Article . 2021 . Peer-reviewed

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From the Avoidance of Double Taxation to the Avoidance of Double Non-Taxation: The Changing Objectives of Tax Treaties

descriptionPublicationkeyboard_double_arrow_right Article 16 Nov 2021 English Publisher:IBFDJournal:Bulletin for International Taxation, volume 75 (eissn: 2352-9202,

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Authors: P.F. Kaka;

doi: 10.59403/1f88y09

From the Avoidance of Double Taxation to the Avoidance of Double Non-Taxation: The Changing Objectives of Tax Treaties

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Abstract

The OECD/G20 Base Erosion and Profit Shifting Project has clarified that relief from double taxation under tax treaties does not extend to double non-taxation. This (new) objective of tax treaties is analysed from the perspective of the preamble and the amendments to the OECD Model (2017) and the related case law.

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