Guidance on the Application of the Principal Purpose Test in Tax Treaties

Journal
Author
Kolosov, V.
Country
International; OECD
Published Date
Issue
Bulletin for International Taxation 2017 (Volume 71), No. 3/4
FormatPDF
EUR
45
| USD
50 (VAT excl.)

This article considers the impact of the principal purpose test, which Action 6 of the OECD/G20 Base Erosion and Profit Shifting initiative has proposed should be included in tax treaties, the certainty it offers with regard to legitimate tax planning and various sources of guidance for its application.