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Preventing Abuse of Tax Treaties -Principal Purpose Test in Multilateral BEPS Agreement-

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3. Preliminary Element of the Principal Purpose Test: The Presence of a Treaty Benefit

According to the PPT provision, the taxpayer must have entered into an arrangement…

What is demanded by the concept of benefit is that the implementation of one or more…

2. Elements of the Principal Purpose Test in the BEPS Agreement
4. Subjective Element of the Principal Purpose Test: “Principal Purpose”