The Resource Does principal purpose test achieve the result of preventing inappropriate use of treaty when it is applied to existing case law?

Does principal purpose test achieve the result of preventing inappropriate use of treaty when it is applied to existing case law?

Label
Does principal purpose test achieve the result of preventing inappropriate use of treaty when it is applied to existing case law?
Title
Does principal purpose test achieve the result of preventing inappropriate use of treaty when it is applied to existing case law?
Creator
Subject
Language
eng
Summary
The line between tax avoidance and tax evasion is indistinct. The classification of a transaction makes the difference between full taxation and reduced/ non-taxation. How this matches a treaty and how this is interpreted by tax authorities and courts makes it problematic. The issue of treaty abuse has its roots from the start of tax and the OECD/G20 Base Erosion and Profit Shifting (BEPS) Action Plans tries to close this gap. A proposed solution is the principal purpose test (PPT). This thesis examines whether the PPT is a solution. It looks at the players - countries/states and improper users of treaties. It explains the PPT and analyses the effect of the PPT with reference to case law
http://library.link/vocab/creatorName
Sanctis, J
Geographic coverage
International
Index
no index present
Language note
English
Literary form
non fiction
http://library.link/vocab/subjectName
  • treaty abuse
  • treaty benefits
  • principal purpose test
  • case law
  • BEPS Project (OECD)
Label
Does principal purpose test achieve the result of preventing inappropriate use of treaty when it is applied to existing case law?
Instantiates
Publication
Extent
58 p.
Label
Does principal purpose test achieve the result of preventing inappropriate use of treaty when it is applied to existing case law?
Publication
Extent
58 p.

Library Locations

    • IBFD Library AmsterdamBorrow it
      Rietlandpark 301, Amsterdam, 1019 DW, NL
      52.3736660 4.9336932
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