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Krishna, V. (2009). Using Beneficial Ownership to Prevent Treaty Shopping. Tax Notes International, 56, 537.

Kemmeren, E. C. C. M. (2010). Legal and economic principles support an origin and import neutrality-based over a residence and export neutrality-based tax treaty polic. In M. Lang, P. Pistone, J. Schuch, C. Staringer, A. Storck, & M. Zagler (Eds.), Tax treaties (pp. 237–316). IBFD.

Hattingh, P. J. (2003). Article 1 of the OECD Model: Historical Background and the Issues Surrounding It. Bulletin de Documentation Fiscale Internationale, 57, 215.

Innes, W. I., Boyle, P. J., Nitikman, J. A., & Fraser Milner Casgrain. (2006). The essential GAAR manual: policies, principles and procedures. CCH Canadian.

Organisation for Economic Co-operation and Development. (2017). Model tax convention on income and on capital: condensed version : 21 November 2017. OECD Publishing.

Malherbe, P. (2015). Elements of international income taxation. Bruylant, Groupe Larcier.

Income taxation is the fuel and vector of the economic policy of many states. This concise book, destined to students, practitioners and policy makers, explains the issues of taxation of transnational income in a world of sovereign states: how to prevent unjust and inefficient double taxation of the same income, by allocating the tax base between source and residence state and properly allowing in the latter for the tax levied in the former? How to prevent abuse by taxpayers or states, furthering tax evasion or avoidance and causing other but equally significant injustices and inefficiencies? Solutions developed over a century of practice are analyzed. That field of the legal art & science is still young and the paradigm for ideal taxation in the global village of the XXIst century is yet to be invented

Duff, D. G. (2018). Tax Treaty Abuse and the Principal Purpose Test - Part 1 International Tax Planning. Canadian Tax Journal, 66(3), 619–678. https://heinonline.org/HOL/P?h=hein.journals/cdntj66&i=687

Disclaimer: This summary was generated by AI based on the content of the source document.

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Diamond, W. H. (with Diamond, D. B.). (2020). Tax havens of the world (loose‑leaf updated 2020, release 170‑3, Vol. 2). M. Bender.

Couzin, R. (with International Bureau of Fiscal Documentation). (2002). Corporate residence and international taxation. IBFD.

Christians, A., & Benoît‑Guay, N. (2021). Status and Structure of Tax Treaties. In J.-P. Vidal, J. Robson, M.-P. Allard, M. Rizqy, & C. Harvey (Eds.), Introduction to international tax in Canada (9th edition.). Thomson Reuters.

Brown, C., & Bogle, J. (2020). Treaty Shopping and the New Multilateral Tax Agreement—Is it Business as Usual in Canada? Dalhousie Law Journal, 43(1), 1. https://digitalcommons.schulichlaw.dal.ca/dlj/vol43/iss1/8

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Baruch, J. (2021, February 8). OpenLux : enquête sur le Luxembourg, coffre-fort de l’Europe. Le Monde. https://www.lemonde.fr/les-decodeurs/visuel/2021/02/08/openlux-enquete-sur-le-luxembourg-coffre-fort-de-l-europe_6069132_4355770.html

Pour dévoiler les dessous du centre financier luxembourgeois, nous avons constitué une vaste base de données inédite, regroupant les propriétaires réels des 140 000 sociétés immatriculées au Luxembourg et le détail de leurs actifs financiers.

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Bammens, N., & De Broe, L. (2010). Treaty Shopping and Avoidance of Abuse. In M. Lang (Ed.), Tax treaties: building bridges between law and economics (p. 51). IBFD.

Lang, M., & Kemmeren, E. C. C. M. (Eds.). (2010). Tax Treaties: Building Bridges between Law and Economics. In Tax treaties: building bridges between law and economics (p. 237). IBFD.

Organisation for Economic Co‑operation and Development. (2021). treaty shopping. In Glossary of Tax Terms. https://www.oecd.org/ctp/glossaryoftaxterms.htm

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Organisation for Economic Co-operation and Development Committee on Fiscal Affairs. (2003). Model tax convention on income and on capital: condensed version, 28 January 2003. OECD.

This publication is the condensed version of the OECD Model Tax Convention on Income and on Capital, which is produced in a loose-leaf format to accommodate yearly updates. This fifth edition contains the full text of the Model Tax Convention as it read on 28 January 2003, but without the historical notes, the detailed list of tax conventions between OECD member countries and the background reports that are included in the loose-leaf version.

Simontacchi, S. (2006). Immovable Property Companies as Defined in Article 13 (4) of the OECD Model. Bulletin for International Taxation, 60(1), 29.

Simontacchi, S. (2007). Taxation of capital gains under the OECD Model Convention: with special regard to immovable property. Kluwer Law International.

Ward, D. A. (2005). The interpretation of income tax treaties with particular reference to the commentaries on the OECD model. International Fiscal Association Canadian Branch.

Li, J. (with Cockfield, A. J., & Wilkie, J. S.). (2018). International taxation in Canada: principles and practices (Fourth edition.). LexisNexis.

The first comprehensive book on Canadian international tax law, International Taxation in Canada {u2013} Principles and Practices was originally published in 2006. Now in its fourth edition, it has become the leading book on this topic in Canada and is the most widely-adopted book for classroom usage at Canadian law schools. A unique and resourceful tool, it provides an understanding of the underlying policy governing international tax rules as well as how foreign tax laws interact with Canadian laws.

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