Comparative International Tax Law

I. I. BRAIDE
BSM 151: COMPARATIVE INTERNATIONAL TAX LAW
WORD COUNT: 5110excluding footnotes

CITL COURSE WORK 2012

Scotia a small oil and gas producing state has a number of DTR Conventions which follow the form of the OECD Model. Its convention with its neighbour Anglia is particularly advantageous reflecting the good relationship with this neighbouring state. However, Scotia has become concerned about the way some individuals and corporations from beyond its boundaries are using its convention with Anglia.

Despite heavy flows of money through the treaty route, there appears to be little advantage to either Scotia or Anglia.

  1. Consider why this might be the situation.

  2. Discuss the formal steps and legal techniques Scotia might take, to reduce what it sees as an abuse of its treaty network using specific examples from the international experience, current and past.

  3. What particular issues might be relevant to the situation in relation to UKCS and oil and gas production?

Approximately 5000 words and submitted by 14th December 2012 1pm.

Contents   Pages
Introduction................                                                     4
An overview of the situation....................                           4- 5
Tax Treaties....................                                                 5- 6
Abuse of Tax Treaties……………………………………….6- 9
Tax Havens………………………………………………………………9- 10
Effects of Tax Havens on Tax Revenue…………………                                     10- 12
Considering the situation at hand.................................                     12- 13
Tax Havens and Tax Evasion.......                                             13- 14
Tax Avoidance and Tax Evasion...............                             14- 16
Steps and legal techniques to reduce an abuse of treaty network....... 16- 20
Relevant issues in relation to the UKCS and Oil & Gasproduction. .........20- 22
Conclusion......................