التعسف في استعمال القانون الجبائي على ضوء الاتفاقيات الثنائية لمنع الازدواج الضريبي

الملخص EN

This study includes a review of the abuse problem in using the tax law in a country, which the taxpayers resort to in order to alleviate the burdens imposed on their incomes.

This arbitrariness also affects the provisions of bilateral tax agreements related to the prevention of double taxation, and this is through the misusing of its provisions in order to benefit from the privileges it recognizes, by resorting to an intermediary person.

This is what the international organizations (OCDE-ONU) have tried to confront within their model agreements, by including provisions that prohibit these practices.

Subsequently, the Group of Twenty in cooperation with the Economic Cooperation and Development' Organization, developed it within the framework of the BEPS agreement.

This is what was not included in the provisions of the Algerian tax agreements, to be fixed later in the texts of the financial laws for the years 2018 and 2019.