The paper will treat in-depth the international tax treatment of trusts, focusing on former old problems, the attempts made to solve them and their current relevance. Thus, the analysis will be conducted regarding both the amendments made to the OECD Model after BEPS and the Multilateral Instrument provisions, assessing their adequacy as solutions to the problems outlined. Lastly, the paper will address the new questions posed by said recent amendments, and it will provide first thoughts on their possible future development.
International taxation of trust after the BEPS project and MLI provisions
Contrino, Angelo
2022
Abstract
The paper will treat in-depth the international tax treatment of trusts, focusing on former old problems, the attempts made to solve them and their current relevance. Thus, the analysis will be conducted regarding both the amendments made to the OECD Model after BEPS and the Multilateral Instrument provisions, assessing their adequacy as solutions to the problems outlined. Lastly, the paper will address the new questions posed by said recent amendments, and it will provide first thoughts on their possible future development.File in questo prodotto:
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