Double Taxation Agreements versus International Tax Planning

The issue of double taxation avoidance is immensely important for tax planning exercised by international holding companies. The present article presents the issue of cross-border related parties employing double taxation agreements for the purpose of devising their tax strategies. In particular, elaboration on double taxation avoidance through the use of countries bearing the characteristics of tax havens deserves attention. The nature of these countries allows for an optimal adoption of strictly defined constructions provided for in double taxation agreements. Analysis also covers the phenomenon of double taxation in the legal and economic sense. This perspective is significant for taxation of international holding companies as well.