International Taxation Judicial Anti Avoidance

Sovereign Power to Levy and Collect Taxes
Evolution and Anti-Abuse Reform of Tax Treaties
Inadequacy of Tax Residency Certificates Against Tax Abuse
Primacy of Commercial Substance and the "Look At" Approach
Source-Based Taxation Principles in Indirect Share Transfers
Supervening Authority of General Anti-Avoidance Rules (GAAR)
Coexistence and Application of Judicial Anti-Avoidance Rules (JAAR)
Scope and Limitations of Threshold Jurisdictional Reviews
Harmonization of International Treaty Obligations and Domestic Legislation
Imperative of Retaining National Tax Sovereignty

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