Article explores the role of economic substance in determining tax treaty benefits in treaty-shopping scenarios.
This article explores whether, and to what extent, the economic substance of an interposed company matters when applying the first step of the Principal Purpose Test (article 29(9) of the OECD Model). In essence, it considers the relevance and role of economic substance in assessing whether a tax treaty benefit was a principal purpose of a treaty-shopping arrangement.
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Mélanie Massant (2025) studied this question.
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