Neale Richmond (Dublin Rathdown, Fine Gael) | Oireachtas source

As stated, the protocol incorporates two minimum standards to combat the abuse of tax treaties as agreed under action six of the BEPS project, which relates to tax planning. The first is contained in Article 1 of the protocol and inserts a new preamble into the original agreement. The preamble contains an express statement emphasising the role of the treaty in combating abuse. The second minimum standard provides for an anti-abuse rule, which denies treaty benefits where obtaining the benefit was one of the principal purposes of the arrangement or transaction entered into. The test is more commonly known as the principal purposes test, PPT, which is contained in Article 4 of the protocol with Jersey.