KPMG article: Impact of principal purpose test (PPT) provisions on holding companies in Latin America

PPT provisions make testing availability of treaty benefits for holding companies more complex

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October 8, 2024

As the implementation of the BEPS 2.0 global anti-base erosion (GloBE) provisions continues to progress this year, many Inclusive Framework members are also continuing to advance the minimum standards from BEPS 1.0 such as the principal purpose test (PPT) or limitation on benefits (LOB) provisions in bilateral income tax treaties. With the increasing adoption and enforcement of these tax treaty-related measures, testing the availability of treaty benefits for holding companies will become more complex.

Read an October 2024 article* prepared by KPMG tax professionals that examines the implications of PPT provisions for taxpayers operating through holding companies in certain Latin American jurisdictions (also available in Spanish and Portuguese).
 

* Reproduced with permission from Tax Management International Journal, 10/3/2024. Copyright @ 2024 by Bloomberg Industry Group, Inc. (800-372-1033) http://www.bloombergindustry.com

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