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

Dhruv Sanghavi

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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
Issue number9
Publication statusPublished - 2016

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