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

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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.
Original languageEnglish
Pages (from-to)520-525
JournalBulletin for International Taxation
Volume70
Issue number9
Publication statusPublished - 2016

Cite this

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title = "The Proposed Tiebreaker Rule in OECD/G20 BEPS Action 6: A Critical Examination of the Possible Motives and Means, and a Potential Alternative",
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.",
author = "Dhruv Sanghavi",
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journal = "Bulletin for International Taxation",
issn = "1819-5490",
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AB - 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.

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SP - 520

EP - 525

JO - Bulletin for International Taxation

JF - Bulletin for International Taxation

SN - 1819-5490

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