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The Principal Purpose Test: A Critical Analysis of Its Substantive and Procedural Aspects – Part 1
8 references·0 citing·16 second hop
The Principal Purpose Test: A Critical Analysis of Its Substantive and Procedural Aspects – Part 1 (2019)The Principal Purpose Test: A Critical An…The Meaning of the Principal Purpose Test: One Ring to Bind Them All? (2019)The Meaning of the Principal …The DNA of the Principal Purpose Test in the Multilateral Instrument (2019)The DNA of the Principal Purp…A Deconstruction of the Principal Purposes Test (2019)A Deconstruction of the Princ…The Principal Purpose Test in the Multilateral Convention: An in-depth Analysis (2018)The Principal Purpose Test in…The Principal Purpose Test (PPT) in BEPS Action 6 and the MLI: Exploring Challenges Arising from Its Legal Implementation and Practical Application (2018)The Principal Purpose Test (P…The Impact of the BEPS Multilateral Instrument on International Tax Policies (2018)The Impact of the BEPS Multil…Treaty Abuse in the Post-BEPS World: Analysis of the Policy Shift and Impact of the Principal Purpose Test for MNE Groups (2017)Treaty Abuse in the Post-BEPS…BEPS Action 6: Tax Treaty Abuse (2015)BEPS Action 6: Tax Treaty Abu…Coordinating the Action of Regional and Global Players during the Shift from Bilateralism to Multilateralism in International Tax Law (2014)Legitimacy and the Making of International Tax Law: The Challenges of Multilateralism (2015)Danish Cases on the Use of Holding Companies for Cross-Border Dividends and Interest – A New Test to Disentangle Abuse from Real Economic Activity? (2020)The "Original Intent" of U. S. International Taxation (1997)Tax Policy for Emerging Markets: Developing Countries (2000)Chapter 6: The OECD Multilateral Instrument: Challenge or Opportunity of Multilateralism in International Tax? (2020)The Relevance of BEPS Materials for Tax Treaty Interpretation (2020)The Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS—Some Thoughts on Complexity and Uncertainty (2018)Dual Residence of Companies under Tax Treaties (2018)In Search of the Digital Nomad – Rethinking the Taxation of Employment Income under Tax Treaties (2019)The PPT in Post-BEPS Tax Treaty Law: It Is a GAAR but Just a GAAR! (2020)Value Creation: A Guiding Light for the Interpretation of Tax Treaties? (2020)Is There an International Minimum Standard on Tax Treaty Shopping after BEPS Action 6? Some Recent Divergent Trends (2022)OECD Base Erosion and Profit Shifting Action 6: The General Anti-Abuse Rule (2015)The Taxation of Technical Services under the United Nations Model Double Taxation Convention: A Rushed – Yet Appropriate – Proposal for (Developing) Countries? (2015)Output Legitimacy Deficits and the Inclusive Framework of the OECD/G20 Base Erosion and Profit Shifting Initiative (2018)
this work references cited by second hop

References

  • 2017Treaty Abuse in the Post-BEPS World: Analysis of the Policy Shift and Impact of the Principal Purpose Test for MNE Groups80 cited
  • 2018The Principal Purpose Test (PPT) in BEPS Action 6 and the MLI: Exploring Challenges Arising from Its Legal Implementation and Practical Application61 cited
  • 2019A Deconstruction of the Principal Purposes Test58 cited
  • 2015BEPS Action 6: Tax Treaty Abuse51 cited
  • 2019The Meaning of the Principal Purpose Test: One Ring to Bind Them All?44 cited
  • 2018The Principal Purpose Test in the Multilateral Convention: An in-depth Analysis34 cited
  • 2018The Impact of the BEPS Multilateral Instrument on International Tax Policies20 cited
  • 2019The DNA of the Principal Purpose Test in the Multilateral Instrument15 cited

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