Tax treaties and tax avoidance : the 2003 revisions to the Commentary to the OECD Model

This article explores the relationship between domestic anti-avoidance rules and tax treaties, including in particular the extent to which tax treaties preclude or limit the application of domestic anti-avoidance rules, and, the extent to which tax treaties themselves contain provisions to prevent their abuse. The article also discusses the revisions to the Commentary dealing with treaty shopping (conduit companies), harmful tax practices, and several matters such as beneficial ownership.