Tax expert presents lecture at London School of Economics

01 May 2018
Craig Elliffe

Professor Craig Elliffe has been invited to speak at the London School of Economics Law Faculty later this month on the topic of the principal purpose test (PPT).

The international tax law specialist’s address entitled The Meaning of the Principal Purpose Test: One Ring to Bind Them All? will outline the vital role PPT provisions will play in preventing international tax avoidance.

Due to the introduction of the Multilateral Convention (MLI) an ever-growing number of the world’s international tax treaties will contain PPT or a treaty-based anti-avoidance rule.

With the introduction of such broad and powerful anti-avoidance rules comes the risk of individual countries, through their revenue authorities and their courts, developing divergent and state-centric views as to the interpretation of the PPT.

Professor Elliffe believes this could lead to enormous problems and great uncertainty in determining and implementing the law. He argues there is a compelling case for the PPT to be interpreted in one consistent harmonised way.

His talk will analyses the PPT rule from a normative position and set out an appropriate basis for the approach to interpreting the PPT. Using all available sources and reports, including examples of the application of the test, he will suggest a comprehensive framework for interpreting the PPT.