https://www.taxtmi.com/manuals?id=2910 Action 6 mandates an express treaty statement that treaties aim to eliminate double taxation without creating non taxation opportunities and requires jurisdictions to implement anti abuse measures by adopting either a Principal Purpose Test with a simplified or detailed Limitation on Benefits rule, the PPT alone, or a detailed LOB combined with measures addressing conduit arrangements. The report also prescribes treaty rules to counter dividend stripping, circumvention of source taxation on property rich companies, dual residency cases and transfers to permanent establishments in low tax jurisdictions, and stresses the complementary role of domestic anti abuse rules. en-us Thu, 22 Jun 2023 17:49:00 +0530 Sat, 27 Jan 2024 13:09:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/manuals?id=2910 Action 6 mandates an express treaty statement that treaties aim to eliminate double taxation without creating non taxation opportunities and requires jurisdictions to implement anti abuse measures by adopting either a Principal Purpose Test with a simplified or detailed Limitation on Benefits rule, the PPT alone, or a detailed LOB combined with measures addressing conduit arrangements. The report also prescribes treaty rules to counter dividend stripping, circumvention of source taxation on property rich companies, dual residency cases and transfers to permanent establishments in low tax jurisdictions, and stresses the complementary role of domestic anti abuse rules. Manuals Income Tax Thu, 22 Jun 2023 17:49:00 +0530 https://www.taxtmi.com/manuals?id=2910