The Principal Purpose Test: A Critical Analysis of Its Substantive and Procedural Aspects – Part 2
Journal
Country
International; OECD
Published Date
Issue
Bulletin for International Taxation 2019 (Volume 73), No. 12
Document
In Part 2 of this article, the author completes his analysis of the new principal purpose test (PPT) contained in article 29(9) of the OECD Model (2017) with regard to its interpretative and procedural implications and how the PPT relates to other anti-avoidance provisions.