Taxation of Bilateral Investments

Tax Treaties after BEPS

Carlo Garbarino, Angelo Sraffa Department of Legal Studies, Bocconi University, Italy and Senior Fellow of the Melbourne Law School, 2018-19

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.

‘As with all of Garbarino’s work, one of the remarkable features of this book is the author’s comprehensive knowledge of tax treaties and tax treaty cases from countries around the world.’
– Kim Brooks, Canadian Tax Journal

‘Garbarino offers his deep knowledge in international tax systems to explain the new international tax planning thresholds. Changes of tax treaty standards derived from the BEPS Project especially, those reflected in the 2017 OECD Model/Commentary offer a basis for insightful guidance from the perspective of the country of destination of the investment. Garbarino analyses the test of the permanent establishment and treaty entitlement and encompasses rules related to corporate vehicles. Investors and their tax advisors, public authorities (including tax judges) and academics will find excellent guidance for their activities in this new international tax scenario.’
——路易斯•爱德华多Schoueri圣保罗大学nd the Brazilian Tax Law Institute, Brazil