000			01929nab a2200265 c 4500
999			_c146455 _d146455
003			ES-MaIEF
005			20220926182820.0
007			ta
008			220919t2022 ne |||||o|||| 00| 0|eng d
040			_aES-MaIEF _bspa _cES-MaIEF
100	1		_967640 _aJalan, Nupur
245		0	_aMost favoured nation clauses in tax treaties _helectrónico _bcomparative analysis and main issues _c Nupur Jalan, Gaetano Manzi and Gert Greve Arcil
500			_aResumen.
520			_aOver time, the use of most favoured nation clauses has seen widespread adoption in double tax treaties, especially in those agreed with developing countries. The use of such clauses, however, does not appear to have been supported frequently by tax policies and/or careful ad hoc analysis, e.g. on the structure, wording and consequences of these provisions in the relevant tax treaty networks. The lack of a model clause in the OECD and UN Model Conventions, and the proliferation of many variants could have played a role in this regard. Because of this, the application of this clause still today triggers many issues that can prevent, for example, its clear and correct interpretation and application and the enjoyment of legitimate treaty benefits by taxpayers or may entail challenges for treaty negotiations. These issues may relate mainly to the nature of such clauses and the policies behind them, as well as to the lack of a clear wording that can facilitate their application in different ways.
650			_aFISCALIDAD INTERNACIONAL _944303
650			_aDOBLE IMPOSICION _942842
650			_aCONVENIOS _941141
650			_aTRATADOS INTERNACIONALES _948608
650		4	_aCLÁUSULA DE NACIÓN MÁS FAVORECIDA _953901
650		4	_aDERECHO COMPARADO _941877
700	1		_968744 _aManzi, Gaetano
700	1		_970035 _aGreve Arcil, Gert
773	0		_9167964 _oWTJ/2022/1 _tWorld Tax Journal _w(IEF)62814 _g v. 14, n. 1, 2022, p. 139-184
942			_cRE