Tax avoidance and tax evasion cause major problems to the assessment and collection of tax and invariably attack the integrity of any tax system. Denis Healey, former UK Chancellor of the Exchequer once said “The difference between tax avoidance and tax evasion is the thickness of a prison...

Global business does its tax planning on an international and multi-jurisdictional basis. Tax Authorities however have remained sovereign and focused on their own tax base. Current economic conditions have sharpened this focus to an acute extent. Tax authorities respond to international tax...

On January 28, 2003 changes were made to the Commentary on Article 1 which deals with the improper use of double tax conventions. Most countries, generally speaking, seem to accept that the general anti-avoidance rules will operate and can be reconciled with the provisions of their double tax...