{"id":{"repo_id":"cape-town","oai_identifier":"oai:open.uct.ac.za:11427/16575"},"canonical_url":"https://search.dev.ndltd.org/etd/cape-town/oai:open.uct.ac.za:11427/16575","repository":{"repo_id":"cape-town","name":"University of Cape Town","base_url":"https://open.uct.ac.za/oai/request"},"display":{"title":"A principled evaluation of the effectiveness of selected aspects of the OECD's BEPS proposals to prevent \"tax treaty abuse\"","abstract":"The BEPS Action 6 Report identified \"tax treaty abuse\", and in particular \"treaty shopping\", as one of the most important sources of BEPS. As such, the objective and purpose of the Action 6 Report is intended to address \"the granting of tax treaty benefits in inappropriate circumstances\" to prevent the perceived \"tax treaty abuse\". This has been a primary focus for the BEPS project. This paper evaluates the effectiveness of selected aspects of the BEPS proposals against this purpose and objectives of the OECD BEPS project. To evaluate the effectiveness of these proposals, this paper examines the development of basic principles to understand what is meant by the term \"tax treaty abuse\". An overview of these developments proposes to provide clarity and ensure that the broader context is conceptualised for the purposes for this paper.","abstract_html":"The BEPS Action 6 Report identified "tax treaty abuse", and in particular "treaty shopping", as one of the most important sources of BEPS. As such, the objective and purpose of the Action 6 Report is intended to address "the granting of tax treaty benefits in inappropriate circumstances" to prevent the perceived "tax treaty abuse". This has been a primary focus for the BEPS project. This paper evaluates the effectiveness of selected aspects of the BEPS proposals against this purpose and objectives of the OECD BEPS project. To evaluate the effectiveness of these proposals, this paper examines the development of basic principles to understand what is meant by the term "tax treaty abuse". An overview of these developments proposes to provide clarity and ensure that the broader context is conceptualised for the purposes for this paper.","abstract_has_math":false,"creators":["Davids, Tharwah"],"institution":"Department of Finance and Tax","degree_name":null,"degree_level":null,"degree_discipline":null,"degree_department":null,"school":null,"contributors":[],"advisors":["Hattingh, Johann","Roeleveld, Jennifer"],"committee_chairs":[],"committee_members":[],"year":2015,"date_issued":"2015","date_published":"2015","updated_at":"2026-07-22T22:23:21Z","subjects":[],"languages":["eng"],"rights":[],"rights_urls":[],"identifier_entries":[]},"links":{"outbound_url":"http://hdl.handle.net/11427/16575","outbound_label":"Handle","outbound_source":"dc:identifier.uri"},"metadata_groups":[{"id":"people","label":"People","entries":[{"key":"dc:contributor.advisor","label":"Advisor","values":["Hattingh, Johann","Roeleveld, Jennifer"]},{"key":"dc:creator","label":"Author","values":["Davids, Tharwah"]}]},{"id":"academic_context","label":"Academic Context","entries":[{"key":"dc:date.accessioned","label":"Dc Date Accessioned","values":["2016-01-26T12:07:16Z"]},{"key":"dc:date.available","label":"Dc Date Available","values":["2016-01-26T12:07:16Z"]},{"key":"dc:date.issued","label":"Date","values":["2015"]},{"key":"dc:publisher.department","label":"Dc Publisher Department","values":["Department of Finance and Tax"]},{"key":"dc:publisher.institution","label":"Dc Publisher Institution","values":["University of Cape Town"]},{"key":"dc:type","label":"Dc Type","values":["Master Thesis"]},{"key":"dc:type.qualificationlevel","label":"Dc Type Qualificationlevel","values":["Masters"]},{"key":"dc:type.qualificationname","label":"Dc Type Qualificationname","values":["MCom"]}]},{"id":"language_rights","label":"Language and Rights","entries":[{"key":"dc:language.iso","label":"Language (ISO)","values":["eng"]}]},{"id":"identifiers","label":"Identifiers","entries":[{"key":"dc:identifier.uri","label":"Identifier URI","values":["http://hdl.handle.net/11427/16575"]}]},{"id":"additional","label":"Additional Metadata","entries":[{"key":"dc:description.abstract","label":"Abstract","values":["The BEPS Action 6 Report identified \"tax treaty abuse\", and in particular \"treaty shopping\", as one of the most important sources of BEPS. As such, the objective and purpose of the Action 6 Report is intended to address \"the granting of tax treaty benefits in inappropriate circumstances\" to prevent the perceived \"tax treaty abuse\". This has been a primary focus for the BEPS project. This paper evaluates the effectiveness of selected aspects of the BEPS proposals against this purpose and objectives of the OECD BEPS project. To evaluate the effectiveness of these proposals, this paper examines the development of basic principles to understand what is meant by the term \"tax treaty abuse\". An overview of these developments proposes to provide clarity and ensure that the broader context is conceptualised for the purposes for this paper."]},{"key":"dc:title","label":"Title","values":["A principled evaluation of the effectiveness of selected aspects of the OECD's BEPS proposals to prevent \"tax treaty abuse\""]}]}],"canonical_facts":{"dc:contributor.advisor":["Hattingh, Johann","Roeleveld, Jennifer"],"dc:creator":["Davids, Tharwah"],"dc:date.accessioned":["2016-01-26T12:07:16Z"],"dc:date.available":["2016-01-26T12:07:16Z"],"dc:date.issued":["2015"],"dc:description.abstract":["The BEPS Action 6 Report identified \"tax treaty abuse\", and in particular \"treaty shopping\", as one of the most important sources of BEPS. As such, the objective and purpose of the Action 6 Report is intended to address \"the granting of tax treaty benefits in inappropriate circumstances\" to prevent the perceived \"tax treaty abuse\". This has been a primary focus for the BEPS project. This paper evaluates the effectiveness of selected aspects of the BEPS proposals against this purpose and objectives of the OECD BEPS project. To evaluate the effectiveness of these proposals, this paper examines the development of basic principles to understand what is meant by the term \"tax treaty abuse\". An overview of these developments proposes to provide clarity and ensure that the broader context is conceptualised for the purposes for this paper."],"dc:identifier.uri":["http://hdl.handle.net/11427/16575"],"dc:language.iso":["eng"],"dc:publisher.department":["Department of Finance and Tax"],"dc:publisher.institution":["University of Cape Town"],"dc:title":["A principled evaluation of the effectiveness of selected aspects of the OECD's BEPS proposals to prevent \"tax treaty abuse\""],"dc:type":["Master Thesis"],"dc:type.qualificationlevel":["Masters"],"dc:type.qualificationname":["MCom"]},"updated_at":"2026-07-22T22:23:21Z"}