2. International Tax Planning


Dr. Heleno Taveira Tôrres
lectronic document
Spanish and English
CIAT April 2022

Contents note:

The CIAT Executive Secretary invites the community to download and read Chapter No. 2 of the Manual for the Control of International Tax Planning, written by Dr. Heleno Taveira Tôrres, called International Tax Planning. Dr. Tôrres illustrates the concept of international tax planning and presents in a didactic way the relevant elements to consider when assessing it. Its content highlights some of the most frequent tax behaviors, which are considered “aggressive”. These include (i) manipulation of the arm’s length principle and/or transfer pricing; (ii) treaty shopping; (iii) recharacterization of activities in the context of double taxation agreements; (iv) creation of double non-taxation strategies; and (v) double deduction strategies.

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