3.3 Tax Treaty Abuse


Enrique Bolado Muñoz and Juan Carlos Trujillo Barroso.
lectronic document
Spanish and English
 CIAT October 2023

Contents note:

The CIAT Executive Secretariat invites you to download and read section 3.3. Tax Treaty Abuse of the Manual for the Control of International Tax Planning, written by Enrique Bolado Muñoz and Juan Carlos Trujillo Barroso.

The chapter analyzes the ways in which taxpayers can take advantage of tax treaties, what the main forms of abuse are and what their effects are on the tax system. Likewise, it describes controversial aspects within this topic, some mechanisms that a tax administration could consider to identify these risks and some issues that have not yet been resolved.

Chapter 3.3 is No. 24 published within the framework of the Manual for the Control of International Tax Planning and is available in English and Spanish. The complete Manual has six sections made up of 42 chapters.

CIAT Subscriptions

Browse through the site without restrictions. Consult and download the contents.

Subscribe to our electronic newsletters:

  • Blog
  • Academic offer (Only in spanish)
  • Newsletter
  • Publications
  • News alert

Activate subscription

CIAT Members

Representatives, Correspondent and Authorized staff (TA)