Internationales Steuerrecht

The DTAs (double taxation agreements) were basically created to protect taxpayers from double access by the tax sovereignty of two states in the case of cross-border activities. However, the ever denser network of DTAs is increasing the effects of abuses. There are opportunities to exploit the possibilities offered by both domestic and DTAs. After a brief introduction to the law of DBA''S, the author Nicole Haas describes in more detail the forms of abuse and their causes. These are made clearer by clarifying the terms in each case using examples. Subsequently, the various abuse regulations under treaty law and domestic abuse regulations are presented and explained in detail. The abuse regulations show how an abusive claim can be prevented.