Group Structuring and Profit Repatriation

Abstract

This article is based on a presentation at the Uppsala conference on Base Erosion and Profit Shifting (BEPS) and its impact on business models, 16–17 June 2016. While discussing the impact from the several BEPS Actions in general terms, the author focuses on the principle purpose test and its potential application on holding companies. He argues that avoiding the multiple or recurrent taxation of profits in the corporate section may conform to the object and purpose of a tax treaty, and that this issue should be further developed in the continued work on BEPS.