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
Date Written: 2016
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: Suggested Citation