Final Report on Action 6 of the OECD/G20 Base Erosion and Profit Shifting Initiative: Prevention of Treaty Abuse

The author, in this article, analyses the Final Report on Action 6 on “Preventing the Granting of Treaty Benefits in Inappropriate Circumstances” of the OECD/G20 Base Erosion and Profit Shifting initiative, especially with regard to the recommended inclusion of a principal purpose test and a new preamble in future tax treaties.