Earth to OECD: Exercise Restraint in Marking a Home Office as PE
status: published
status: published
The paper deals with the analysis of the legal aspects of the principal purpose test rule (PPT-Rule) and the general anti-abuse rules contained in the Brazil-Poland Double Tax Convention concluded on 20th September, 2022, in the light of Brazil’s international tax treaty policy and practice. The Authors discuss issues related to the interaction bet...