Tax Treaty Proportionality

Principle

Tax treaty proportionality is a principle asserting that measures taken within double taxation agreements, particularly anti-abuse rules, should be appropriate and not excessive in relation to their intended objectives. This ensures that legitimate cross-border investment and trade are not unduly hindered by overly broad or stringent provisions. For crypto derivatives, this means anti-avoidance rules should target genuine abuse without stifling innovation or legitimate hedging activities. It seeks a balanced approach to fiscal policy.