The CIAT Executive Secretariat invites you to download and read chapter “3.17 Misuse of Special Purpose entities” of the Manual on International Tax Planning Control, written by Professor 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.

This is the 33rd chapter published as part of the “Manual for the control of International Tax Planning“, available in English and Spanish. The complete Manual has six chapters comprised of 42 sections. New sections will be published soon.