Examination of the Anti-Avoidance Measures to Counter Tax Treaty Abuse/Shopping.

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dc.contributor.authorIsau Olatunji Ahmed
dc.date.accessioned2026-05-14T10:31:35Z
dc.date.available2026-05-14T10:31:35Z
dc.date.issued2021
dc.description.abstractA Double Tax Treaty (DTT) is a bilateral agreement between two countries aimed at eliminating double taxation to encourage international trade and investment. Usually, the benefit of relief of double taxation provided under a DTT is only available to taxpayers who are resident in both or one of the countries that is a party to DTT. The implication of this is that, taxpayers who are not resident in either of the country that is a party to DTT are ineligible to enjoy the benefit of relief of double taxation provided by DTT. However, in recent years, through the ingenuity and assistance of accountants, lawyers, tax consultants and advisors, taxpayers are now able to set up structures which makes it possible for them to enjoy the benefit offered by a DTT even though they are not resident in either of the country that is a party to DTT. This constitute an improper use of tax treaty to gain a tax advantage which is now generally referred to as ‘tax treaty abuse/shopping’. ‘Tax treaty abuse/shopping’ is considered as a form of tax avoidance or evasion that can negatively impact on government’s revenue generation. It is in this regard that the Organisation for Economic Co-operation and Development (OECD) introduced certain anti-avoidance measures to counter treaty abuse/shopping. The objective of this article is to examine the various anti-avoidance measures introduced by OECD to counter treaty abuse/shopping. The article also examines the current position of the Nigerian government on tax treaty abuse/shopping.
dc.identifier.citationAl-Hikmah University Journal of Private and Business Law. 1(1): 76-89
dc.identifier.issn2811-1532
dc.identifier.urihttps://kwasuspace.kwasu.edu.ng/handle/123456789/7135
dc.language.isoen
dc.publisherPrivate and Business Law Department, Al-Hikmah University, Ilorin.
dc.titleExamination of the Anti-Avoidance Measures to Counter Tax Treaty Abuse/Shopping.
dc.typeArticle
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