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  4. OECD-Art1
  5. Week 6: Showcase and reflect
  6. Capstone Case Dossier

Capstone Case Dossier

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

Download and study the full case dossier: MegaCorp NV - a multi-tier corporate structure with a CIV investor layer.

NL HoldCo -> IE Co (royalties) -> US OpCo (operating profits)

External investor: Luxembourg SICAV holds 35% of NL HoldCo

Dossier includes: corporate chats, relevant treaty article, financial summary

No additional reading required - prior week materials provide all legal basis

Completion requirements:
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