Substance in International Tax Law: DEMPE Approach, Substantial Activity Requirement and Beneficial Ownership

by Florian Navisotschnigg

The notion of 'substance' is proving to be central to the OECD's base erosion and profit shifting (BEPS) project, particularly in the area of taxation of intangibles. In this book, this notoriously hard-to-define concept is examined from three distinct angles: transfer pricing (DEMPE Approach), harmful tax practices (Substantial Activity Requirement), and tax treaties (Beneficial Ownership).

In a thoroughgoing investigation using the practical...

• Format: Hardcover
• Language: English
• ISBN: 9403548959
• ISBN13: 9789403548951
• Release Date: August 2022
• Publisher: Kluwer Law International
• Length: 208 Pages
• Weight: 1.03 lbs.
• Dimensions: 0.5" x 6.1" x 9.2"