The Resource The principal purpose test in tax treaties under BEPS 6

The principal purpose test in tax treaties under BEPS 6

Label
The principal purpose test in tax treaties under BEPS 6
Title
The principal purpose test in tax treaties under BEPS 6
Creator
Subject
Language
eng
Summary
In report 6 of the base erosion and profit shifting (BEPS) Action Plan, Preventing the Granting of Treaty Benefits in Inappropriate Circumstances, the OECD proposes (amongst others) to include a principal purpose test (PPT) in tax treaties. Under this test a treaty benefit shall not be granted if it is reasonable to conclude that obtaining that benefit was one of the principal purposes of any arrangement or transaction (subjective test), unless it is established that granting that benefit in these circumstances would be in accordance with the object and purpose of the relevant provisions of the treaty (objective test). The subjective test is, from the viewpoint of the tax authorities a relatively 'easy' test. The objective test, however, can provide for some relief for taxpayers. In this article the PPT is being investigated and discussed. Especially, attention is given to the objective test. An attempt is being made to develop practical guidance to interpret the PPT, based on Dutch case law and doctrine
Citation source
In: Intertax. - Alphen aan den Rijn. - Vol. 44 (2016),
http://library.link/vocab/creatorName
Kok, R
Geographic coverage
International
Language note
English
http://library.link/vocab/subjectName
  • BEPS Project (OECD)
  • principal purpose test
  • tax treaty
  • case law
  • treaty abuse
  • treaty benefits
Label
The principal purpose test in tax treaties under BEPS 6
Instantiates
Publication
Label
The principal purpose test in tax treaties under BEPS 6
Publication

Library Locations

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