"Object and Purpose in Tax Treaty Law - Importance and Limits"
 

Object and purpose, under the Vienna Convention (1969), have been a relevant means of interpretation for a long time. It has arguably become even more important for tax treaty law in recent years due to the introduction of the principle purpose test (PPT) rule as a result of the final report on BEPS Action 6 (2015). The PPT rule refers to the object and purpose of the relevant tax treaty provisions. It may deny tax treaty benefits in cases where these benefits are not in accordance with that object and purpose. The inaugural lecture is going to address the role of the object and purpose under the Vienna Convention on the Law of Treaties (1969) and under the PPT rule. Is the PPT rule deviating from the established rules of interpretation to give preference to the object and purpose even beyond the wording?

Click here for the live stream.