3.17. Misuse of special purpose entities
| AUTHOR | |
|---|---|
| Hans van den Hurk and Pilar Coutinho Elói | |
| lectronic document | |
| Spanish and English | |
| CIAT | September 2024 |
Contents note:
The CIAT Executive Secretariat invites you to download and read chapter “3.17. Misuse of Special Purpose entities” from the Manual for the Control of International Tax Planning, written by the Hans van den Hurk and Pilar Coutinho Elói.
This chapter provides a didactic approach to the use of Special Purpose Companies, Holding Companies, and the Search for a Favorable Business Treaty by companies. It highlights key aspects such as the basic structures used, bona fide exclusions as safeguards, and mechanisms to control the abuse of these strategies. In addition, the chapter offers practical examples and a checklist for dealing with real situations, providing tax administrations with tools to combat abusive practices.
Chapter 3.17. is No. 33 published within the framework of the “Manual for the Control of International Tax Planning” and is available in English and Spanish. The complete Manual consists of six sections made up of 42 chapters.