Objective or Subjective – Anti-treaty shopping policy in select Asian jurisdictions in the post-BEPS world
BEPS Action 6 proposes two distinct anti abuse measures to be incorporated into the OECD Model Convention and subsequently into the various bilateral tax treaties: A Limitation on Benefits (LoB) clause and Principal Purpose Test (PPT). While both anti abuse measures are new to the OECD Model Convent...
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Main Authors: | BAIK, Andy, Petutschnig, Matthias |
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Format: | text |
Language: | English |
Published: |
Institutional Knowledge at Singapore Management University
2018
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Online Access: | https://ink.library.smu.edu.sg/soa_research/1850 https://ink.library.smu.edu.sg/context/soa_research/article/2875/viewcontent/SSRN_id3104976.pdf |
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Institution: | Singapore Management University |
Language: | English |
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