(Un)constitutionality of the provision on the principal purpose of transaction or arrangement test from the tax treaties
The principal purpose of transaction or arrangement test (PPT) contained in MLI authorises tax authorities to deny a treaty benefit. The structure of PPT shows that tax authorities were given wide discretion. Its wording does not determine what will be taxed in the source country once the benefit is...
| Main Authors: | , |
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| Format: | Article |
| Language: | English |
| Published: |
University of Belgrade, Faculty of Law, Belgrade, Serbia
2019-01-01
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| Series: | Anali Pravnog Fakulteta u Beogradu |
| Subjects: | |
| Online Access: | https://scindeks-clanci.ceon.rs/data/pdf/0003-2565/2019/0003-25651902007P.pdf |