The Resource Principal purpose test and wholly artificial arrangements, can substance rules really solve the problem of conduit companies and treaty shopping?

Principal purpose test and wholly artificial arrangements, can substance rules really solve the problem of conduit companies and treaty shopping?

Label
Principal purpose test and wholly artificial arrangements, can substance rules really solve the problem of conduit companies and treaty shopping?
Title
Principal purpose test and wholly artificial arrangements, can substance rules really solve the problem of conduit companies and treaty shopping?
Creator
Subject
Language
eng
Summary
This thesis examines the question "Can the Principal Purpose Test rule, as it is foreseeable to be applied, be effective against the forms of tax planning that it seeks to prevent?". It analyses the PPT rule as it was established by the 2015 final report on Action 6 of the BEPS project (later included in the 2017 OECD model convention and commentary). It analyses the limits that will be imposed to the rule in its application at the national level (for his thesis the European Union is chosen as an example of local limits). It establishes a "working standard", a set of steps or rules that need to be followed to apply the PPT rule. Finally, it applies the working standard of the PPT rule to cases of tax planning strategies in order to determine if the PPT rule, as it is foreseeable to be applied, fulfills its goal of preventing treaty abuse through treaty shopping and conduit companies
http://library.link/vocab/creatorName
Montenegro Guillinta, E.A
Geographic coverage
  • International
  • European Union
Index
no index present
Language note
English
Literary form
non fiction
http://library.link/vocab/subjectName
  • principal purpose test
  • treaty shopping
  • BEPS Action Plan
  • GAAR
  • treaty abuse
  • tax structure
  • international tax planning
  • conduit company
Label
Principal purpose test and wholly artificial arrangements, can substance rules really solve the problem of conduit companies and treaty shopping?
Instantiates
Publication
Extent
55 p.
Label
Principal purpose test and wholly artificial arrangements, can substance rules really solve the problem of conduit companies and treaty shopping?
Publication
Extent
55 p.

Library Locations

    • IBFD Library AmsterdamBorrow it
      Rietlandpark 301, Amsterdam, 1019 DW, NL
      52.37366609999999 4.9336932
Processing Feedback ...