Treaty Anti-Abuse Rules and Corporate Tax Structuring

Following the implementation of the G20/OECD BEPS Action Plan, in particular Action 6 on treaty anti-abuse rules and the multilateral instrument (MLI), international tax structuring practices have to take into account the potential application of different types of anti-abuse rules. This webinar will explore how multinationals and tax authorities ought to look at the various treaty anti-abuse rules to ascertain their practical impact and potential application on corporate tax structuring practices.

Topics Covered

Block 1:

  • Types of treaty anti-abuse rules
  • Anti-fragmentation rules on PE
  • Anti-contract splitting
  • Beneficial ownership
  • Dividend stripping
  • Limitation on benefits
  • Principal purpose test
  • Switch-over rules
  • Substance over form

Block 2: The impact of treaty anti abuse rules on corporate tax structuring

  • Illustration on practical implication of some anti-abuse rules in corporate tax structuring, focussing in particular on the principal purpose test

Block 3: Cases

  • Cases illustrating the impact of anti-abuse rules in corporate tax structuring

Learning Objectives

After this module, the participants will be able to:

  • Identify different types of treaty anti-abuse rules
  • Differentiate the role of, and the relation between, different types of anti-abuse rules
  • Determine the relationship between tax treaties and domestic provisions
  • Examine implications of treaty (and domestic) anti-abuse rules from a corporate tax structuring perspective


  • Hans Pijl, IBFD
  • Carlos Gutiérrez Puente, IBFD

Field of study


Who should participate

This webinar would benefit tax professionals working in multinational groups, tax and legal advisory firms and governments:

  • Inhouse tax professionals and advisers looking to assess whether and how anti-abuse rules are applicable to corporate tax structures
  • Legal professionals assessing the risk of tax controversy associated with tax structures
  • Government officials reviewing and auditing the application of anti-abuse rules to corporate tax structures

Course level and prerequisites

This is an intermediate-level webinar. Participants in this webinar are expected to have at least 3 to 5 years of experience in international tax and are familiar with the key concepts of international tax law.

Advance preparation

No advance preparation is needed. Participants are expected to be familiar with the key concepts of international tax law.

Interactive webinar – “Group Internet Based” (live webinar only)

During live webinars, it is possible to interact with the presenters via a chat message function. Please note that questions are answered based on relevance, order of receipt and available time. Additionally, participants in the live webinar are invited to answer poll questions. Participants will also have access to the on-demand version for a further 12 months from the live date.

Date of live broadcast: 13 Oct 2022

On-demand webinar

On-demand webinars are intended for individual self-study only. Unlike live webinars, they are not open to interactive participation nor do they offer the assistance of a real-time instructor. Access to on-demand webinars is granted for a period of 12 months.

Continuing Professional Education

Many accrediting organizations will grant continuing professional education (CPE) credit(s) for an IBFD audio-visual broadcast. It is advisable, however, that you check with your accrediting body as to whether this applies only to live webinars or to on-demand webinars as well. International Bureau of Fiscal Documentation (IBFD) is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of CPE on the National Registry of CPE Sponsors. State boards of accountancy have the final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors through its website: NASBA CPE credit – 1 (only applicable to live webinar).

Webinar registration details

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