BEPS, MLI, Principal purpose test

(Leiden University)/ /1 Comment

Background Action 6 of BEPS introduced the principal purpose test (PPT) as one of the Minimum Standards to be implemented by the countries/jurisdictions taking part in the BEPS Inclusive Framework (IF). The PPT has been also introduced in the Multilateral Instrument (MLI), in force since 1 July 2018. Even though the choice given to countries…

OECD, Tax Policy

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The recent (February 2019) OECD document for public consultation introduced two proposals to address the challenges of taxation, the first one is the revised profit allocation and nexus rules in the digital economy (Section 2) and the second one is the global anti-base erosion proposal (Section 3). Even though the document is titled challenges of…