3.4. Abuse of Domestic Rules


José  Manuel Castro Arango
lectronic document
Spanish and English
 CIAT December 2023

Contents note:

The CIAT Executive Secretariat invites you to download and read chapter 3.4. Abuse of Domestic Rules, of the “Manual for the Control of International Tax Planning”, written by José Manuel Castro Arango.

This section analyzes various cases of abuse of domestic tax rules and examines in detail cases of evasion (e.g.: evading through the concept of residency, evasion of the permanent establishment rules, evasion through hybrid financial instruments or debt). In addition, mechanisms are described which confront the abuse of tax regulations (e.g.: anti-avoidance clauses and doctrines, general and specific anti-abuse regulations, other internal regulations and provisions in tax treaties).

Chapter 3.4. is No. 25 published within the framework of the “Manual for the Control of International Tax Planning” and is available in English and Spanish.

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