000			02269nab a2200265 c 4500
999			_c140421 _d140421
003			ES-MaIEF
005			20221107163846.0
007			ta
008			190410t2019 ne ||||oo|||| 00| 0|eng d
040			_aES-MaIEF _bspa _cES-MaIEF
041			_aeng
100	1		_aElliffe, Craig M. _960059
245		4	_aThe meaning of the principal purposes test _bone ring to bind them all? _c Craig Elliffe
260			_c2019
500			_aDisponible únicamente en formato electrónico en la Biblioteca del IEF.
500			_aResumen.
520			_aDue to the introduction of the Multilateral Convention (MLI), an ever-growing number of the world's international tax treaties will contain a treaty-based anti-avoidance rule known as the principal purpose test (PPT). These PPT provisions will almost certainly play an extremely important role in preventing international tax avoidance. With the introduction of such broad and powerful anti-avoidance rules comes the risk of individual countries, through their revenue authorities and their courts, developing divergent and state-centric views as to the interpretation of the PPT. This risk is quite considerable, and there are many reasons why a harmonized basis of interpretation may not, in reality, emerge. If courts pursue an individual and diverse approach to the interpretation of the PPT, the same transaction will be viewed as being effective in one jurisdiction and ineffective in another. From a broader perspective, this is undesirable, and it should not occur for policy and interpretative reasons. Why is the case for interpreting the PPT consistently, with a common meaning, so compelling? There is one major reason, and it is an obvious one: the PPT can now be found in thousands of treaties, and it is exactly the same test in all of these. It is clear that an international autonomous meaning is intended to be introduced through the uniform adoption of the PPT.
650		4	_944303 _aFISCALIDAD INTERNACIONAL
650		4	_941141 _aCONVENIOS
650		4	_948608 _aTRATADOS INTERNACIONALES
650		4	_931085 _aCLÁUSULA DEL PROPÓSITO PRINCIPAL
650		4	_963564 _aABUSO DE TRATADOS
773	0		_9160099 _oWTJ/2019/1 _tWorld Tax Journal _w (IEF)62814 _g v. 11, n. 1, February 2019, p. 47-76
942			_cRE