Limitation on Benefits: from the US Model 2006 to the ACT Group Litigation

Article Abstract:

The United States includes Limitation on Benefits (LoB) clauses in their tax treaties to prevent treaty shopping by residents of third countries. An examination of LoB clause compatibility with European Union Laws is presented with a focus on the European Court of Justice's ruling in the Advance Corporate Tax Group litigation case.

United Kingdom, Legal issues & crime, Legal/Government Regulation, Company legal issue, Cases, Powers and duties, European Court of Justice

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Some thoughts on further refinement of the concept of place of effective management for tax treaty purposes

Article Abstract:

The concept of place of effective management for use in tax treaties remains ambiguous due to differences in fiscal and corporate governance culture. Any OECD proposal should account for these differences and provide a clear definition of the concept.

Netherlands, Corporate governance, Terminology, Report

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US tax scene: new treaty and protocol with Belgium signed

Article Abstract:

The key features of the new income tax treaty signed between the United States and Belgium are presented. The benefits of the treaty for both countries are examined.

International economic relations, Belgium, United States foreign relations, Income tax, Belgian foreign relations

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