David is the partner-incharge of the Deloitte Australia Tax Insights & Policy group. David has over 30 years experience in corporate income tax and international tax covering a wide range of tax issues across various industry sectors. David has worked in Malaysia, Singapore and New York.
BEPS actions 6 – preventing treaty abuse – and 7 – preventing the artificial avoidance of Permanent Establishment status – triggered a reshaping of anti-avoidance, anti-abuse and anti-treaty shopping rules, both in domestic laws and in treaty provisions.
This session will explore the principal purpose test, as well as a range of other similar measures. These rules are still largely untested, and collectively make it clear that establishing the entitlement to treaty benefits is only half the battle.