The Resource Introduction of the principal purpose test and discretionary benefits provisions into Singapore's tax treaties : not as black as it is painted : part 1- reasons
Introduction of the principal purpose test and discretionary benefits provisions into Singapore's tax treaties : not as black as it is painted : part 1- reasons
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The item Introduction of the principal purpose test and discretionary benefits provisions into Singapore's tax treaties : not as black as it is painted : part 1- reasons 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 purpose test and discretionary benefits provisions into Singapore's tax treaties : not as black as it is painted : part 1- reasons 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 comprehensive two-part article 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 (MLI), and the potential consequences of that decision. Part 1 of the article focuses on the reasons for, and manner of, introducing the PPT while Part 2 examines the potential consequences, with specific reference to channelling highly mobile income to tax havens via Singapore. The author argues that Singapore's introduction of the PPT is unlikely to deter foreign direct investment and jeopardize the country's current attractive business and tax-competitive position. Rather, the way that Singapore introduced the PPT - by way of the MLI together with the discretionary benefits provision - appears to be in line with its policy of granting tax benefits (including treaty benefits) using the tax authority's broad discretionary powers and deploying a purposive approach to interpretation of the law
- Language
- eng
- Label
- Introduction of the principal purpose test and discretionary benefits provisions into Singapore's tax treaties : not as black as it is painted : part 1- reasons
- Title
- Introduction of the principal purpose test and discretionary benefits provisions into Singapore's tax treaties : not as black as it is painted : part 1- reasons
- Language
- eng
- Summary
- This comprehensive two-part article 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 (MLI), and the potential consequences of that decision. Part 1 of the article focuses on the reasons for, and manner of, introducing the PPT while Part 2 examines the potential consequences, with specific reference to channelling highly mobile income to tax havens via Singapore. The author argues that Singapore's introduction of the PPT is unlikely to deter foreign direct investment and jeopardize the country's current attractive business and tax-competitive position. Rather, the way that Singapore introduced the PPT - by way of the MLI together with the discretionary benefits provision - appears to be in line with its policy of granting tax benefits (including treaty benefits) using the tax authority's broad discretionary powers and deploying a purposive approach to interpretation of the law
- Citation source
- In: Asia-Pacific tax bulletin. - Amsterdam. - Vol. 24 (2018), no. 2 ; 10 p
- http://library.link/vocab/creatorName
- Kuźniacki, B
- Geographic coverage
- Asia
- Language note
- English
- http://library.link/vocab/subjectName
-
- principal purpose test
- MLI
- foreign investment
- treaty benefits
- Label
- Introduction of the principal purpose test and discretionary benefits provisions into Singapore's tax treaties : not as black as it is painted : part 1- reasons
- Label
- Introduction of the principal purpose test and discretionary benefits provisions into Singapore's tax treaties : not as black as it is painted : part 1- reasons
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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-purpose-test-and/u3bG_og2obE/" 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-purpose-test-and/u3bG_og2obE/">Introduction of the principal purpose test and discretionary benefits provisions into Singapore's tax treaties : not as black as it is painted : part 1- reasons</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>
