The Relevance of “Economic Substance” for the Purpose-Based Test of the PPT
New
Journal
International; OECD
Bulletin for International Taxation 2026 (Volume 80), No. 1
This article explores whether, and to what extent, the economic substance of an interposed company matters when applying the first step of the Principal Purpose Test (article 29(9) of the OECD Model). In essence, it considers the relevance and role of economic substance in assessing whether a tax treaty benefit was a principal purpose of a treaty-shopping arrangement.