The Resource The interaction of the principal purpose test (and the guiding principle) with treaty and domestic anti-avoidance rules

The interaction of the principal purpose test (and the guiding principle) with treaty and domestic anti-avoidance rules

Label
The interaction of the principal purpose test (and the guiding principle) with treaty and domestic anti-avoidance rules
Title
The interaction of the principal purpose test (and the guiding principle) with treaty and domestic anti-avoidance rules
Creator
Subject
Language
eng
Summary
In this contribution, the author, firstly, discusses the interaction of the principal purpose test (PPT) with the inherent anti-abuse rule. Secondly, the author discusses the relationship of the PPT with existing treaty general anti-avoidance rules (GAARs) and specific anti-avoidance rules (SAARs) such as the limitation of benefits (LoB) clause, the beneficial ownership clause, holding/time period provisions introduced in the articles dealing with dividends/capital gains as well as the anti-abuse rule with respect to permanent establishments (PEs) in a third State. Lastly, the author analyses the interaction of the PPT with domestic anti-avoidance rules such as judicial doctrines, statutory GAARs and SAARs
Citation source
In: Intertax. - Alphen aan den Rijn. - Vol. 46 (2018), no. 2 ; p. 115-123
http://library.link/vocab/creatorName
Chand, V
Geographic coverage
North America
Language note
English
http://library.link/vocab/subjectName
  • principal purpose test
  • GAAR
  • anti-avoidance
  • LoB
  • beneficial ownership
  • holding period
Label
The interaction of the principal purpose test (and the guiding principle) with treaty and domestic anti-avoidance rules
Instantiates
Publication
Label
The interaction of the principal purpose test (and the guiding principle) with treaty and domestic anti-avoidance rules
Publication

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