Treaty Abuse in the Post-BEPS World: Analysis of the Policy Shift and Impact of the Principal Purpose Test for MNE Groups
Details
State: Public
Version: Final published version
License: Not specified
Serval ID
serval:BIB_C4BF952C7C7F
Type
Article: article from journal or magazin.
Collection
Publications
Institution
Title
Treaty Abuse in the Post-BEPS World: Analysis of the Policy Shift and Impact of the Principal Purpose Test for MNE Groups
Journal
Bulletin for International Taxation
ISSN
0007-4624
Publication state
Published
Issued date
28/12/2017
Volume
72
Number
1
Pages
31-55
Language
english
Abstract
In this article, the author discusses treaty abuse in the Post-BEPS world and focuses on the practical impact of the Principal Purpose Test (PPT rule) for MNE groups. The article analyses in particular the meaning of substance under the PPT rule and the consequences of denial of treaty benefits.
Publisher's website
Create date
25/02/2019 17:33
Last modification date
02/09/2019 23:18
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