![]() |
An analysis of tax treaty provisions to structure an international transaction or operation so as to take advantage of a particular tax treaty. The term is normally applied to situations where a person not resident of either of the treaty countries establishes an entity in one of the treaty countries in order to obtain the treaty benefits, i.e. to reduce or eliminate tax. For instance, a taxpayer resident in one country who wishes to invest in another country will not make a direct investment in that country, but instead will use a series of entities located in various jurisdictions to avail himself of the benefits in the tax treaties between countries concerned. Thus, the taxpayer is able to claim treaty benefits to which he would not otherwise be entitled.
|
© Trustmoore. All Rights Reserved. |