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Article
Finding the Purpose of Tax TreatyProvisions Under GAAR: Lessons From Alta Energy
Tax Notes International, January 10, 2022, p. 147
  • Jinyan Li, Osgoode Hall Law School of York University
Document Type
Article
Publication Date
1-1-2022
Abstract

Establishing the object and purpose of tax treaty provisions lies at the heart of applying antiabuse rules, such as general antiavoidance rules under domestic law and the principal purpose test (PPT) in tax treaties. Tax planning arrangements like treaty shopping, designed to obtain treaty benefits, are not abusive unless they contravene the object and purpose of the provisions relied upon by the taxpayer.

Citation Information
Jinyan Li. "Finding the Purpose of Tax TreatyProvisions Under GAAR: Lessons From Alta Energy" Tax Notes International, January 10, 2022, p. 147 (2022)
Available at: http://works.bepress.com/jinyan_li/179/