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  4. OECD-Art1
  5. Week 3: Collective Investment Vehicles (CIVs) – Treaty Status of Funds

Mastering OECD Model Convention Article 1: Persons covered & Anti-Abuse rules

Section outline

  • General
  • Week 1: Introduction to Article 1 – Defining "Persons Covered"
  • Week 2: Article 1(2) – Fiscally Transparent Entities & Partnerships
  • Week 3: Collective Investment Vehicles (CIVs) – Treaty Status of Funds
  • Week 4: Article 1(3) – Saving Clauses & Domestic Taxation Rights
  • Week 5: Article 1(4) & 1(5) – Prevention of Treaty Abuse & The PPT
  • Week 6: Showcase and reflect

  • Evaluating when investment funds can claim treaty benefits under the OECD Commentary.

    • Intro on Collective investment vehicles Book
      Students must
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