The Signalling Function of Article 29(9) of the OECD Model – The “Principal Purpose Test”

Abstract

Article 29(9) of the OECD Model sets out the principal purpose test (PPT) according to the findings of the OECD/G20 Base Erosion and Profit Shifting Project. The PPT does not represent a legal basis for denying treaty benefits but merely emphasizes the necessity for purposive interpretation.