Therefore, in principle, it can be argued that the PPT is one of the minimum international tax standards applicable by countries members of the BEPS Inclusive Framework and/or MLI (Cyprus is only signatory of the MLI). Even though the choice given to countries was either (i) PPT (with or without detailed or simplified LOB) or (ii) detailed LOB with anti-conduit financing arrangements, the peer review report on Action 6 (March 2019) show that countries are choosing to implement option (i) and that option (ii) has only be chosen until now by the United States (IRC § 1.881-3) and section 3.2.2. The PPT has been also introduced in the Multilateral Instrument (MLI) in force since 1 July 2018. The PPT, the BEPS Inclusive Framework and MLIĪction 6 of BEPS introduced the principal purpose test (PPT) as one of the Minimum Standards to be implemented by the countries participating in the BEPS Inclusive Framework. The first blogpost addresses PPT and MLI, the second blogpost the interaction between PPT GAARs and the third blogpost the PPT as minimum standard in light of the EU Standard of Good Tax Governance and of Global Tax Governance. This is a serie of three blogposts regarding the Principal Purpose Test (PPT) of BEPS Action 6.
0 kommentar(er)
