Taxation of Bilateral Investments

The OECD's guidance on combatting tax avoidance strategies associated with Base Erosion and Profit Sharing (BEPS) methods is complex and accompanied by a wealth of literature. This book is the first to provide a concise and accessible overview of counter BEPS measures in the OECD Model and Commentary, allowing readers to gain a practical understanding of how the measures can impact the taxation of bilateral investments protected by tax treaties.

Key features include:

• Practical analysis of tax treaties from the perspective of the country which is the destination of foreign investment
• Chapters that explore specific aspects of doing business in a destination country which employs the measures set out in the OECD Model and Commentary
• Explanation of how BEPS treaty rules affect a range of corporate tax strategies including: permanent establishment, use of corporate vehicles and intra-group transactions
• Information on administrative matters associated with BEPS, focusing on dispute settlement and cooperation in enforcement.

Providing a succinct and practical approach to the topic, this book will be an insightful resource for those practising in the field of international taxation as well as corporate in-house counsel. Researchers and students seeking clear information on BEPS and its real world application affecting tax treaties will also benefit from this concise guide.