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Treaty shopping : la fin d'un problème fiscal international? / Treaty shopping: the end of an international tax issue?

Treaty Shopping can be defined as the "abuse" of tax conventions; it is a major international taxation topic. Its importance is increasing since the beginning of the 80's and the enactment of specific anti treaty shopping measures. / Those specific measures are the purpose of this thesis. Is treaty shopping a solved problem? Are those measures, taken principally by the undisputed leader of this policy, the United States, entirely efficient? / In order to answer those questions, a brief study of the phenomenon of treaty shopping is needed. The first part of this thesis deals with this issue. / The measures themselves are analyzed in the second part. Basically, we can classify them in two categories, the national and the limitation on benefits incorporated in tax conventions. Both of them present weaknesses and approximations. In those circumstances, it would be difficult to admit the end of treaty shopping. Moreover, those measures have raised new problems that must be addressed firstly in order to envisage an end to the practice of treaty shopping.

Identiferoai:union.ndltd.org:LACETR/oai:collectionscanada.gc.ca:QMM.31568
Date January 1999
CreatorsDhoukar, Malek.
PublisherMcGill University
Source SetsLibrary and Archives Canada ETDs Repository / Centre d'archives des thèses électroniques de Bibliothèque et Archives Canada
LanguageFrench
Detected LanguageEnglish
TypeElectronic Thesis or Dissertation
Formatapplication/pdf
CoverageMaster of Laws (Institute of Comparative Law.)
RightsAll items in eScholarship@McGill are protected by copyright with all rights reserved unless otherwise indicated.
Relationalephsysno: 001786662, proquestno: MQ70543, Theses scanned by UMI/ProQuest.

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