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In Part 1 of this article, the author examines the new principal purpose test (PPT) contained in article 29(9) of the OECD Model (2017) with regard to its substantive and interpretative implications and how the PPT relates to other anti-avoidance provisions.
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Stored only when both papers are in the corpus — 12 citations exist upstream.
Papers that cite the same references — the relational fallback while embeddings are still backfilling.
Imported from OpenAlex (CC0) — nothing here is generated.