In 2015, the OECD released its final report on Base Erosion and Profit Shifting (BEPS) Action 6. Among several new rules, the report introduced the Principal Purpose Test (PPT), as a minimum standard, the counter tax treaty abuse. Since then, the PPT has been incorporated in more than 1,000 tax treaties through the Multilateral Tax Instrument (MLI) or bilateral tax treaty negotiations. It should be noted that the PPT has also been incorporated in the tax treaty policy of several Asian countries. Against this background, the purpose of this webinar session is to discuss the core elements of the PPT and the latest global developments that could impact the interpretation of this provision.

Topics covered in this webinar include:

• Concept of Treaty shopping.
• Core elements of the PPT Rule.
• Interaction of the PPT rule with other Anti-Abuse Rules.
• Global case that could impact the interpretation of the PPT Rule (e.g., case law from France, UK, Canada, the European Court of Justice, and other countries).
• Panel discussion with selected tax administration on detecting and auditing treaty abuse matters
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Contact us

For further inquiries, please send us an email at taxreta@adb.org.