The Proposed Tiebreaker Rule in OECD/G20 BEPS Action 6: A Critical Examination of the Possible Motives and Means, and a Potential Alternative

(2016) 70 Bulletin for International Taxation 9, pp. 520-525

6 Pages Posted: 14 Sep 2016 Last revised: 13 Feb 2017

See all articles by Dhruv Sanghavi

Dhruv Sanghavi

affiliation not provided to SSRN

Date Written: 2016

Abstract

In this article, the author critically examines the proposed tiebreaker rule in the OECD’s Final Report on Action 6 of the Base Erosion and Profit Shifting (BEPS) project, and the motives behind the proposal. The author concludes by suggesting an alternative, which he argues is a more effective means to achieve the intended ends.

Keywords: OECD, BEPS, Dual Residence, Place of Effective Management, International Tax, Tax Treaties, Anti Avoidance, E-Commerce

Suggested Citation

Sanghavi, Dhruv, The Proposed Tiebreaker Rule in OECD/G20 BEPS Action 6: A Critical Examination of the Possible Motives and Means, and a Potential Alternative (2016). (2016) 70 Bulletin for International Taxation 9, pp. 520-525, Available at SSRN: https://ssrn.com/abstract=2834175 or http://dx.doi.org/10.2139/ssrn.2834175

Dhruv Sanghavi (Contact Author)

affiliation not provided to SSRN

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