European Union - The Principal Purpose Test under BEPS Action 6: Is the OECD Proposal Compliant with EU Law?
- European Union
- O. Koriak
- European Taxation, 2016 (Volume 56), No 12
- 9 November 2016
In this article, the author contributes to the discussion on the BEPS project and its compatibility with EU law, focusing specifically on the PPT rule. The question addressed is whether or not Member States will be able to implement the proposed rule into their tax treaty networks in compliance with EU law. In addition, the PPT formula chosen by the European Commission in the Anti Tax Avoidance Package is analysed.