Includes bibliographical references (pages 261-269) and index.
Pt. I. Introduction. 1. Introduction -- Pt. II. Double Taxation. 2. Occurrence of double taxation. 3. Rationale for the avoidance of double taxation. 4. Avoidance of double taxation -- Pt. III. Tax Treaties. 5. History and purpose. 6. Structure -- Pt. IV. Improper Use of Tax Treaties. 7. The concept of improper use of tax treaties. 8. Treaty shopping and other perceived improper use of tax treaties -- Pt. V. Efforts to Combat Improper Use of Tax Treaties. 9. Interpretation and application of substance over form principles. 10. Provisions in or based on domestic legislation. 11. Treaty provisions -- Pt. VI. Conclusion and Recommendations. 12. Conclusion and recommendations.