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The “Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting” – An analysis of the Principal Purpose Test from the perspective of Finnish tax treaty practice

JFT 2/2018 s. 123–172
9.5.2018
Asiantuntija-artikkeli

The heated political debate on aggressive tax practices of multinational entities starts to produce tangible outcomes. On 7th of June 2017 Finland signed the so-called “Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting” (MLI). Certain rules related to the abuse of tax treaties will, as a result, start to become applicable soon. They can be seen as quite disruptive in international tax law. Hence, it appears worthwhile to present them to a broader audience. The reader will be introduced into the topic via a short outline of the flaws in the current international tax system leading to concerns on international (OECD, UN) and supranational (EU) level. Embedding it into the bigger picture of action against “Base Erosion and Profit Shifting”, the MLI and one of the Finnish choices – the Principal Purpose Test – will be elaborated. (Edilex-toimitus)

Asiasanat
• Beskattning - Internationell företagsverksamhet - Internationell överenskommelse