Tax Treaties and Abuse: The Effectiveness of the Principal Purpose Test and Some of Its Shortcomings

Journal
Hurk, H.T.P.M. van den
International; OECD
Bulletin for International Taxation 2021 (Volume 75), No. 6
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In this article, Hans van den Hurk sets out his views on the abuse of tax treaties and the effectiveness of the provisions contained in article 29(9) of the OECD Model regarding the principal purpose test (PPT), together with a consideration of some of the drawbacks of the PPT.