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Alesco New Zealand Limited v CIR: Concerns over the broad discretion in the application of the New Zealand GAAR

Elliffe, Craig; Keating, Mark - In: British tax review (2013) 3, pp. 275-286

Persistent link: https://www.econbiz.de/10010162844

OECD/International - Unfinished Business: Domestic Thin Capitalization Rules and the Non-Discrimination Article in the OECD Model - This article considers the nature of the relationship between domestic thin capitalization rules and the non-discrimination article in the OECD Model, with a particular focus on foreign ownership and article 24(5). This question is addressed in an international ...

Elliffe, Craig - In: Bulletin for international taxation 67 (2013) 1, pp. 26-40

Persistent link: https://www.econbiz.de/10010075137

OECD/International - Unfinished Business: Domestic Thin Capitalization Rules and the Non-Discrimination Article in the OECD Model - This article considers the nature of the relationship between domestic thin capitalization rules and the non-discrimination article in the OECD Model, with a particular focus on foreign ownership and article 24(5). This question is addressed in an international ...

Elliffe, Craig - In: Bulletin for international taxation 67 (2013) 1, pp. 26-40

Persistent link: https://www.econbiz.de/10010075492

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