Tax treaties exploited for profit, leading to global tax evasion schemes.
The article discusses how tax treaties between countries can be misused, focusing on the Netherlands and the United States. It explains why double taxation is a problem and how tax treaties aim to prevent it. The authors explore the history and purpose of tax treaties, as well as the concept of improper use. They suggest using substance over form principles and domestic laws to combat misuse. The main goal is to address improper use of tax treaties and recommend ways to prevent it.