the purpose or one of the main purposes

2 articles available

Jonathan Schwarz (Temple Tax Chambers; King’s College London) for article 3(2), treaty interpretation, burden of proof, OECD Commetary, UN Commentary

Even before introduction of the BEPS PPT, the UK has had purpose-based provisions in various forms, designed to limit access to treaty benefits in its double tax treaties since the 1960’s. Its…

When the UK introduced its diverted profits tax, I was telephoned by a lawyer at the US Treasury. He wanted to know whether the “just and reasonable” apportionment of profits, in certain…