The application of the BEPS Action Plan’s PPT clause in the network of double taxation agreements signed by Colombia La aplicación de la cláusula PPT del Plan de Acción BEPS en la red de convenios de doble imposición suscritos por Colombia

Abstract

In 2013 the OECD began the development of the BEPS Action Plan, consisting of 15 actions in which measures are proposed to, among other things, avoid the abusive use of Double Taxation Agreements, which concluded with the subscription of a Multilateral Agreement that allows the simultaneous modification of the DTA signed by the States. Among the measures proposed by the OECD in the BEPs Action plan to avoid de abusive use of the DTA is to include in the agreement a general anti-abuse clause consisting in the application of the Principal Purpose Test (PPT), which could have direct effects on taxpayers, so it is pertinent an necessary to analyze the scope and application od that clause in the network of DTA signed by Colombia so to give taxpayers and administrations a clearer vision of the figure.