The Resource Introduction of the principal pupose test and discretionary benefits provisions into Singapore's tax treaties : not as black as it is painted
Introduction of the principal pupose test and discretionary benefits provisions into Singapore's tax treaties : not as black as it is painted
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The item Introduction of the principal pupose test and discretionary benefits provisions into Singapore's tax treaties : not as black as it is painted represents a specific, individual, material embodiment of a distinct intellectual or artistic creation found in International Bureau of Fiscal Documentation.This item is available to borrow from 1 library branch.
Resource Information
The item Introduction of the principal pupose test and discretionary benefits provisions into Singapore's tax treaties : not as black as it is painted represents a specific, individual, material embodiment of a distinct intellectual or artistic creation found in International Bureau of Fiscal Documentation.
This item is available to borrow from 1 library branch.
- Summary
- This is the second part of a comprehensive two-part article, which addresses the manner in which, and the possible reasons why, Singapore adopted the principal purpose test (PPT) and the discretionary benefits provisions in the OECD's Multilateral Instrument, and the potential consequences of that decision. This part examines hypothetical consequences of the incorporation of the PPT and the discretionary benefits provision into Singapore's tax treaties. The author challenges certain aspects of mainstream scholarship, according to which the introduction of the PPT by offshore financial centres will most likely have a negative impact on efforts to attract foreign direct investment or otherwise jeopardize their business and tax competitive position. He concludes that Singapore's - and other jurisdictions with a similar approach to taxation of income - way of meeting the minimum standard under the OECD's BEPS Action 6 is quite bizarre: on the one hand, it may still allow highly mobile income to be channelled to tax havens and otherwise attract FDIs. On the other hand, it may allow the tax authorities of Singapore's tax treaty partners that are high-tax jurisdictions to deny benefits under their treaties with Singapore to arrangements or transactions with economic substance and non-tax business purpose
- Language
- eng
- Label
- Introduction of the principal pupose test and discretionary benefits provisions into Singapore's tax treaties : not as black as it is painted
- Title
- Introduction of the principal pupose test and discretionary benefits provisions into Singapore's tax treaties : not as black as it is painted
- Language
- eng
- Summary
- This is the second part of a comprehensive two-part article, which addresses the manner in which, and the possible reasons why, Singapore adopted the principal purpose test (PPT) and the discretionary benefits provisions in the OECD's Multilateral Instrument, and the potential consequences of that decision. This part examines hypothetical consequences of the incorporation of the PPT and the discretionary benefits provision into Singapore's tax treaties. The author challenges certain aspects of mainstream scholarship, according to which the introduction of the PPT by offshore financial centres will most likely have a negative impact on efforts to attract foreign direct investment or otherwise jeopardize their business and tax competitive position. He concludes that Singapore's - and other jurisdictions with a similar approach to taxation of income - way of meeting the minimum standard under the OECD's BEPS Action 6 is quite bizarre: on the one hand, it may still allow highly mobile income to be channelled to tax havens and otherwise attract FDIs. On the other hand, it may allow the tax authorities of Singapore's tax treaty partners that are high-tax jurisdictions to deny benefits under their treaties with Singapore to arrangements or transactions with economic substance and non-tax business purpose
- Citation source
- In: Asia-Pacific tax bulletin. - Amsterdam. - Vol. 24 (2018), no. 3 ; 14 p
- http://library.link/vocab/creatorName
- Kuźniacki, B
- Geographic coverage
- Asia
- Language note
- English
- http://library.link/vocab/subjectName
-
- principal purpose test
- tax treaty
- MLI
- BEPS Project (OECD)
- foreign investment
- Label
- Introduction of the principal pupose test and discretionary benefits provisions into Singapore's tax treaties : not as black as it is painted
- Label
- Introduction of the principal pupose test and discretionary benefits provisions into Singapore's tax treaties : not as black as it is painted
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<div class="citation" vocab="http://schema.org/"><i class="fa fa-external-link-square fa-fw"></i> Data from <span resource="http://link.library.ibfd.org/portal/Introduction-of-the-principal-pupose-test-and/P2Ip6ButSbM/" typeof="Book http://bibfra.me/vocab/lite/Item"><span property="name http://bibfra.me/vocab/lite/label"><a href="http://link.library.ibfd.org/portal/Introduction-of-the-principal-pupose-test-and/P2Ip6ButSbM/">Introduction of the principal pupose test and discretionary benefits provisions into Singapore's tax treaties : not as black as it is painted</a></span> - <span property="potentialAction" typeOf="OrganizeAction"><span property="agent" typeof="LibrarySystem http://library.link/vocab/LibrarySystem" resource="http://link.library.ibfd.org/"><span property="name http://bibfra.me/vocab/lite/label"><a property="url" href="https://link.library.ibfd.org/">International Bureau of Fiscal Documentation</a></span></span></span></span></div>
