BEPS Action 6 - An inclusion of anti-abuse measures in tax treaties to prevent the improper use of a tax treaty - Are the measures suggested in BEPS Action 6 necessary from a Swedish perspective?
The thesis provides an overview of the relationship between tax treaties and domestic law and issues that arise if a contracting state uses domestic anti-avoidance rules to prevent the improper use of a tax treaty. Improper use of a tax treaty is an issue addressed in the BEPS Action 6 report. The suggestion is to include a limitation-on-benefits clause in the OECD Model Convention, a principal pu
