Abstract
Abstract This chapter focuses on the Principal Purpose Test (PPT), which is the multilateral minimum standard to combat the improper use of double taxation conventions. It notes the PPT architecture being inspired by the ‘guiding principle’ inserted in the OECD Commentaries in 2003. Moreover, the PPT has been codified in Article 29(9) OECD and UN Model Tax Conventions. Since the PPT is rooted in the Base Erosion and Profit Shifting (BEPS) initiative, questions arose on the capability of the PPT to influence the conditions governing access to tax treaty benefits. The chapter notes how the PPT, as a general anti-avoidance rule (GAAR), is incapable of building into tax treaty law requirements that were never intended.
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