and PPT rule; iii) the PPT rule solely, or iv) the LOB rule complemented by a mechanism designed to counteract ‘conduit financing arrangements’.14 1.2 Subject and purpose When one thinks about BEPS as a soft law instrument, which of course cannot override provisions of EU law, but has been committed to gradual

15 Oct 2018 the OECD's minimum standard on tax treaty abuse under BEPS Action 6. and context for understanding BEPS Action 6, the MLI and the PPT.

Like many other aspects of the OECD’s recommendations contained within the 15 BEPS Actions, the new anti-abuse rules are proposed to be included in a multilateral instrument which currently is under development. BEPS Actions addresses much of the DE BEPS concern, but also sets out additional measures countries may consider. The report states that the Task Force on the Digital Economy (TFDE) will continue its work by monitoring new DE business models and the effectiveness of BEPS measures with the objective of issuing a report on its work by 2020. BEPS Update for Real Estate Funds PPT adopted, starting with the German treaty Changes adopted, starting with the German treaty CBC starts 1 January 2016 BEPS Webcast #6 - Update on project 1. LIVE WEBCAST UPDATE ON BEPS PROJECT 2015 DELIVERABLES AND BEYOND 12 February 2015 3:00pm – 4:00pm (CET) PPT are well-known both in domestic and tax treaty practice. In the author’s opinion, the source of the confusion is also due to the fact that the PPT is part of a holistic project – the OECD/G20 Base Erosion and Profit Shifting (BEPS) initiative – founded The webinar ‘International taxation, BEPS and Principal Purpose Test (PPT)’ provides an introduction to international income taxation of business transactions.

14 Jul 2018 sources of BEPS concerns. • Three alternative rules to address tax treaty abuse. • Principal purpose test (PPT) rule. • PPT rule, supplemented 26 May 2016 Certain criteria in the form of a "Limitation of Benefits" ("LOB") provision and/or " Principal Purpose Test" ("PPT") need to be met in order to ensure The OECD BEPS Action 6 report contains a principal purpose test rule (PPT rule) for the purpose of combating abuse of tax treaties. This PPT rule is also 1 Apr 2019 Will including the PPT in Singapore's DTAs make it more difficult for Singapore implement the tax treaty related BEPS recommendations.

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Principal purposes test (PPT) rule (subjective rule) Text of PPT rule (same text is given in MI as well): “Notwithstanding the other provisions of this Convention, a benefit under this Convention shall not be granted in respect of an item of income or capital if it is reasonable to conclude, having regard to all

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Särskilt genom åtgärd 13 i BEPS införs en landsspecifik rapportering för vissa multinationella företag till nationella

ALI-NAKYEA & ASSOCIATES - ppt download. Arbetets titel: BEPS och aggressiv skatteplanering - En fallstudie om Google. Handledare: Ett test för det huvudsakliga syftet, eller ett så kallat PPT test, som är. Treaty Related Measures to Prevent BEPS. OECD.

the PPT alone; or a detailed version of the LOB rule together with a mechanism (such as a treaty rule that might take the form of a PPT rule restricted to conduit arrangements, or domestic anti-abuse rules or judicial doctrines that would achieve a similar result) that would deal with conduit arrangements not already dealt with in tax treaties. Minimum standards for parts of the international tax system were agreed under the base erosion and profit shifting (BEPS) Action Plan as part of recommendations published in October 2015. OECD’s BEPS initiative—Deloitte’s sixth annual survey The purpose of Deloitte’s 2019 survey was to gauge multinationals’ views on the progress of the implementation of the BEPS project recommendations and their views on consequential developments within their organizations given the changing tax landscape. The ECOFIN Council has decided in April 2018 that this standard should also include in addition to transparency, exchange of information, fair taxation also the BEPS 4 Minimum Standards including the PPT of BEPS Action 6 (FISC 180 ECOFIN 364).
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for the purpose of combating abuse of tax treaties. The PPT rule is applicable when ‘it is reasonable to conclude’ that obtaining a benefit is one of the principal purposes of an arrangement (the reasonableness test). as BEPS).

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Samling. JM, EM, doktorand Kenneth Hellsten - ppt ladda ner. Internationell BEPS påverkar svenska företag med utlandspersonal. Varsågod.

15 Oct 2018 the OECD's minimum standard on tax treaty abuse under BEPS Action 6. and context for understanding BEPS Action 6, the MLI and the PPT. 21 Nov 2014 Aligning the Commentary on the PPT rule and the LOB discretionary inappropriate circumstances”) of the BEPS Action Plan (the “Report”) 27 Sep 2017 Future tax treaties will therefore contain at least two and potentially even three different concepts: an LoB clause, a PPT and the beneficial 19 Mar 2018 Principle purpose test (PPT): BEPS Action 6 also requires the introduction of a PPT (Article 7 MLI). Under this test, a treaty benefit is denied if it Professor Oguttu is a member of the BEPS Monitoring Group.

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2019-10-09

A dialogue with Skatteverket.