The eye of the needle: Is one of your purposes tax avoidance?

We have all become familiar with the expression in the PPT set out in article 7(1) of the MLI and article 29(9) of the 2017 OECD Model  where “obtaining that benefit was one of the principal purposes of any arrangement or transaction”.  Discerning which is a principal purpose is one of the main challenges in … Continue reading The eye of the needle: Is one of your purposes tax avoidance?