References

• 2017Treaty Abuse in the Post-BEPS World: Analysis of the Policy Shift and Impact of the Principal Purpose Test for MNE Groups80 cited
• 2019A Deconstruction of the Principal Purposes Test58 cited
• 2015BEPS Action 6: Tax Treaty Abuse51 cited
• 2010Beneficial Ownership: Current Trends50 cited
• 2017The Reasonableness Test of the Principal Purpose Test Rule in OECD BEPS Action 6 (Tax Treaty Abuse) versus the EU Principle of Legal Certainty and the EU Abuse of Law Case Law49 cited
• 2019The Meaning of the Principal Purpose Test: One Ring to Bind Them All?44 cited
• 2017GAARs and Treaties: From the Guiding Principle to the Principal Purpose Test. What Have We Gained from BEPS Action 6?36 cited
• 2016Anti-Tax Avoidance Directive (2016/1164): New EU Policy Horizons32 cited
• 2010The Evolution of the Term “Beneficial Ownership” in Relation to International Taxation over the Past 45 Years25 cited
• 2015Treaty Shopping and Limitation on Benefits Articles in the Context of the OECD Base Erosion and Profit Shifting Project17 cited
• 2013Limitation on Benefits Articles in Income Tax Treaties: The Current State of Play14 cited
• 2012Searching for the Uncertain Rationale Underlying the US Treasury's Anti-treaty Shopping Policy14 cited
• 2012US Treaty Anti-Avoidance Rules: An Overview and Assessment14 cited

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