The interaction of the principal purpose test (and the guiding principle) with treaty and domestic anti-avoidance rules Vikram Chand
By: Chand, Vikram
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Material type: 
ArticlePublisher: 2018Subject(s): EROSIÓN DE LA BASE IMPONIBLE Y TRASLADO DE BENEFICIOS | EVASION FISCAL | PREVENCION | PROGRAMAS | APLICACION | CONVENIOS | TRATADOS INTERNACIONALES | CLÁUSULA DEL PROPÓSITO PRINCIPAL | FISCALIDAD INTERNACIONAL | ELUSION FISCAL
In:
Intertax v. 46, n. 2, February 2018, p. 115-123Summary: In this contribution, the author, firstly, discusses the interaction of the principal purpose test (PPT) with the inherent anti-abuse rule. Secondly, the author discusses the relationship of the PPT with existing treaty general anti-avoidance rules (GAARs) and specific anti-avoidance rules (SAARs) such as the limitation of benefits (LoB) clause, the beneficial ownership clause, holding/time period provisions introduced in the articles dealing with dividends/capital gains as well as the anti-abuse rule with respect to permanent establishments (PEs) in a third State. Lastly, the author analyses the interaction of the PPT with domestic anti-avoidance rules such as judicial doctrines, statutory GAARs and SAARs.
| Item type | Current location | Home library | Call number | Status | Date due | Barcode |
|---|---|---|---|---|---|---|
| Artículos | IEF | IEF | OP 2141/2018/2-3 (Browse shelf) | Available | OP 2141/2018/2-3 |
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Bibliografía.
In this contribution, the author, firstly, discusses the interaction of the principal purpose test (PPT) with the inherent anti-abuse rule. Secondly, the author discusses the relationship of the PPT with existing treaty general anti-avoidance rules (GAARs) and specific anti-avoidance rules (SAARs) such as the limitation of benefits (LoB) clause, the beneficial ownership clause, holding/time period provisions introduced in the articles dealing with dividends/capital gains as well as the anti-abuse rule with respect to permanent establishments (PEs) in a third State. Lastly, the author analyses the interaction of the PPT with domestic anti-avoidance rules such as judicial doctrines, statutory GAARs and SAARs.
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