Is the End of Nationality Planning Nigh? Key Parallels between Double Taxation Treaties and IIAs
The two worlds are not that apart. In March 2021, UNCTAD released a report which addresses the potential implications of International Investment Agreements (IIAs) for tax-related measures. According to UNCTAD, both the IIAs regime and double taxation treaties (DTTs) address similar challenges, eg. indirect ownership, mailbox companies and time-sensitive restructuring. The report emphasizes that some…