The article argues that despite the fanfare around it, the outcome of the BEPS project is unlikely to be dramatic, at least in the short term. Beyond a period of increased legal uncertainty and aggressive enforcement by some countries, it expects little substantive change in tax treaties. The...

In this article, the author discusses the assistance of examples of the application of the principal purpose test (PPT) listed in the Commentary on Article 29(9) of the OECD Model (2017) in establishing the legal certainty of the test. To demonstrate the weak elements of the PPT, the author...

The issue of General Anti-Avoidance Rules and treaties is a legal problem as old as double tax conventions themselves. However, the BEPS Project, materialized in 15 Actions and particularly in the Final Report of BEPS Actions 6, involves a radical change in the very physiognomy of the problem....

The aim of this paper is to assess the feasibility to introduce the OECD-BEPS measures to deal with aggressive tax planning in South America and Sub-Saharan Africa. The BEPS and its Action Plan have been developed by the OECD following the G20 mandate and it provides new international tax...

The Multilateral Convention to Implement Tax Treaty Measures to Prevent Base Erosion and Profit Shifting (MLI) has been described as “an historical turning point in the area of international taxation” which introduces a third layer of tax rules for the taxation of cross-border transactions...

The extensive OECD/G20 Base Erosion and Profit Shifting Project (BEPS) in its Final Report on Action 6 “Preventing the Granting of Treaty Benefits in Inappropriate Circumstances” (Action 6 Final Report) focused on tax treaty abuse as one of the biggest concerns of the BEPS initiative. Action...

In this article, the author explores and advocates the use of an artificial intelligence tax treaty assistant with regard to resolving issues and problems in respect of the principal purpose test as proposed in relation to the OECD/G20 Base Erosion and Profit Shifting initiative. As the PPT is...

This study was drafted as the EU topical report for IFA's general report on the topic reconstructing the treaty network and deals with the intersection of three areas: i) European Union law; ii) the OECD's Base Erosion and Profit Shifting project (BEPS) and its implementation, and; iii) member...