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46 Intertax 1 (2018)

handle is hein.kluwer/intrtax0046 and id is 1 raw text is: 






















Editorials
2           Intertax: What's Ahead
            Ana Paula Dourado


3           Are We Compatible?: On Multilateral Tax Coordination
            Ana Paula Dourado



Articles
6           McBEPS: The MLI - The First Multilateral Tax Treaty that Has Never Been
            Yariv Brauner


18          The Principal Purpose Test in the Multilateral Convention: An in-depth Analysis
            Vikram Chand


45          Implementation in Practice of the Principal Purpose Test in the Multilateral
            Convention
            Marcus Livio Gomes


58          Interplay Between the Principal Purpose Test in the Multilateral BEPS Convention
            and the Beneficial Ownership Clause as Treaty Anti-Avoidance Tool Targeting
            Holding Structures
            Elio Andrea Palmitessa


68          The Limitation on Benefits (LOB) Provision in BEPS Action 6/MLI:
            Ineffective Overreaction of Mind-Numbing Complexity - Part 1
            Blafej Kuiniacki



Country note

80          US Perspectives on the Multilateral Instrument
            Mindy Herzfeld


86          Article Index


92          Author Index


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