Essays about: "PPT rule"

Found 2 essays containing the words PPT rule.

1. 1. Is BEPS Action 6 “Preventing Treaty abuse” compatible with the EU Law concept of abuse?

   University essay from Lunds universitet/Institutionen för handelsrätt

   Author : Amela Juka; [2016]
   Keywords : Treaty shopping; Treaty abuse; Anti-abuse rules; Double non-taxation; CJEU; LOB Clause; PPT rule; wholly artificial arrangements ; GAAR; BEPS; BEPS action 6; OECD; EU Fundamental Freedoms; EU law; Law and Political Science;

   Abstract : In September 2015, the OECD released the final report on BEPS action 6. The main purpose of the action 6 is the prevention of "granting treaty benefits in inappropriate circumstances". Regarding the prevention of treaty abuse the OECD presented three main recommendations. These actions are only proposals and therefore they constitute soft law. READ MORE

3. 2. The Principal Purpose Test under BEPS Action 6: Does the OECD Proposal Fit the EU Legal Framework?

   University essay from Lunds universitet/Institutionen för handelsrätt

   Author : Oleksandr Koriak; [2016]
   Keywords : Treaty Shopping; Treaty Abuse; BEPS; GAAR; PPT; Principal Purpose Test; Anti-Abuse Rules; EU Fundamental Freedoms; Law and Political Science;

   Abstract : On October 5, 2015, the Organization for Economic Cooperation and Development published the final package of 15 actions under the BEPS initiative. This package, in particular, includes the Final Report on Action 6 – ‘Preventing the granting of treaty benefits in inappropriate circumstances’, which is intended to provide countries with the ‘minimum level of protection against treaty abuse’. READ MORE