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www.oecd.org/tax/beps/beps-action-6-preventing-the-granting-of-treaty- i) the Principal Purposes Test (PPT) rule included in paragraph 26 of the Report  Department of Business Law. 'The Principal Purpose Test under BEPS Action 6: Does the OECD Proposal Fit the EU Legal. Framework?' by. Oleksandr Koriak. a principal purpose test (PPT) equivalent to paragraph 9 of Article 29 of the 2017 OECD Model Tax Convention together with either a simplified or a detailed  Feb 22, 2020 KATA KUNCI: MLI, PPT, Tax Treaty, Treaty Abuse, BEPS Action 6 Development, the Principal Purpose Test (PPT) has been introduced as. The Principal Purposes Test introduced under BEPS Action 6 will apply to all treaties covered by the MLI, while an additional simplified Limitation on Benefits  Rule', Bulleting for International Taxation, IBFD, p.

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74, n. o. 7, pp. 655-664 Principal Purpose Test. What Have We Gained from BEPS Action 6? Intertax, Volume 45, 6–7/2017, s.

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Koriak, Oleksandr LU HARN60 20161 Department of Business Law. Mark; Abstract On October 5, 2015, the Organization for Economic Cooperation and Development published the final package of 15 actions under the BEPS initiative. In report 6 of the BEPS action plan, Preventing the Granting of Treaty Benefits in Inappropriate Circumstances, the Organisation for Economic Co-operation and Development (OECD) proposes (amongst others) to include a principal purpose test (PPT) in tax treaties. Action 6 of the BEPS Action Plan identified treaty abuse, and in particular treaty shopping, as one of the most important sources of BEPS concerns. One of it Principle purposes test rule: The paper proposes a broadly drafted general purpose rule aimed at removing treaty benefits where one of the principal purposes of arrangements or transactions is to obtain treaty benefits.

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The Principal Purposes Test (PPT) in BEPS Action 6/MLI: Exploring Challenges arising from its Legal Implementation and Practical Application Abstract: This study contains a comprehensive, in-depth analysis of the principal purposes test (PPT) designed by the Organization for Economic Cooperation and Development (OECD) as Home > IBFD Products > Journal Articles > European Taxation > European Union - The Principal Purpose Test under BEPS Action 6: Is the OECD Proposal Compliant with EU Law? European Union - The Principal Purpose Test under BEPS Action 6: Is the OECD Proposal Compliant with EU Law? Action 6 of the OECD’s Base Erosion and Profit Shifting (BEPS) report introduces a “principal purpose test” (PPT) which aims to prevent the application of the benefit granted by a DTT in cases where “one of the principal purposes of transactions or arrangements is to obtain treaty benefits […] unless it is established that granting these benefits would be in accordance with the object and purpose of the provisions of the treaty.” BEPS principal purpose test and customary international law Irma Johanna Mosquera Valderrama1 Leiden University, Steenschuur 25, 2311ES Leiden, Netherlands Email: i.j.mosquera.valderrama@law.leidenuniv.nl Abstract The overall aim of this article is to analyse the principal purpose test as an emerging rule of customary In addition to this principal purpose test (PPT), the Action 6 Report provides two versions (a simplified and detailed version) of a specific anti-abuse rule, the limitation on benefits (LOB) provision, which limits the availability of treaty benefits to persons that meet one or more categorized tests listed in paragraphs 9 to 13 of Aritcle 7.

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While both anti abuse measures are new to the OECD Model Convention, various countries around the The MLI also implements the BEPS Action 6 minimum standard by implementing a principal purpose test (PPT). Under the PPT rule, a tax treaty benefit is denied where one of the principal purposes of an arrangement or transaction is to directly or indirectly obtain the benefit, unless the granting of that benefit in the circumstances would be in accordance with the object and purpose of the OECD. On 15 July 2019, the OECD announced that it is now gathering input on the implementation of the BEPS Action 14 minimum standard in relation to the review of the ninth batch of jurisdictions (Andorra, Anguilla, Bahamas, Bermuda, British Virgin Islands, Cayman Islands, Faroe Islands, Macau (China), Morocco and Tunisia) and invites taxpayers to submit their input related to their OECD. On 26 July 2019, Eswatini joined the BEPS Inclusive Framework, bringing the total number of jurisdictions to 132. As a new BEPS member, Eswatini is committed to comply with the BEPS minimum standards, which are contained in Action 5 (countering harmful tax practices), Action 6 (preventing treaty abuse), Action 13 (transfer pricing documentation) and Action 14 (enhancing dispute resolution). Principal Purpose Test.

World Tax Journal 10 (2), 2018. 12: 2018: The Limitation on Benefits (LOB) Provision in BEPS Action 6/MLI: Ineffective Overreaction of Mind-Numbing Complexity–Part 1. The UAE has chosen to include additional wording in the preamble of their DTAs stating the DTAs should not be used for treaty abuse (BEPS Action 6 minimum standard). The UAE has chosen to include a Principal Purpose Test (“PPT”) with the ability to refer to a competent authority for final assessment of the availability of treaty benefits (BEPS Action 6 minimum standard). Action 6 was intended to counter treaty shopping so that, in the example in Figure 1, the conduit SPV would not be able to claim treaty relief and the operating company's payments would be fully subject to withholding tax. The Action 6 proposals were published in October 2015, together with the other fourteen BEPS Actions.
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548. V. Analysis A. Diverging Views on the Principal Purpose Test 553. Dec 9, 2017 Furthermore, neither Article 7 nor the BEPS Action 6 Report provides much guidance as to how this inquiry should be conducted. The problem  Dec 3, 2018 To address perceived treaty abuse, the final report on BEPS Action 6 5 recommends that a "principal purpose test" be added to tax treaties. 7 http://www.oecd.org/tax/treaties/discussion-draft-action-6-prevent-treaty-abuse. htm. 8 The principle purpose test in Article 10, paragraph 7 of the Netherlands  Aug 11, 2017 Action 6 of the OECD's Base Erosion and Profit Shifting (BEPS) report introduces a "principal purpose test" (PPT) which aims to prevent the  Jun 2, 2018 In 2015 the BEPS Project under the Final Report of Action 6 establish a Principal Purpose Test.

Michael, BEPS Action 6: Introducing an Antiabuse Rule in Tax Treaties, Tax Notes International, vol. 74, n. o. 7, pp.
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B Kuźniacki. World Tax Journal 10 (2), 2018.

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The Principal Purposes Test introduced under BEPS Action 6 will apply to all treaties covered by the MLI, while an additional simplified Limitation on Benefits  Rule', Bulleting for International Taxation, IBFD, p. 602.

To determine whether or not one of the principal purposes of any person concerned with an arrange-ment or transaction is to obtain benefits under the Convention, it is important to undertake an objective 6.