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

doi:10.2139/SSRN.2834175

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^*

^*Corresponding author for this work

Research output: Contribution to journal › Article › Academic › peer-review

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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 language	English
Pages (from-to)	520-525
Journal	Bulletin for International Taxation
Volume	70
Issue number	9
DOIs	https://doi.org/10.2139/SSRN.2834175
Publication status	Published - 2016

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10.2139/SSRN.2834175

IFA President YIN Scientific Award
Sanghavi, D. (Recipient), 2017
Prize: Prize (including medals and awards) › Professional

Cite this

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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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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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Prizes

IFA President YIN Scientific Award

Cite this