Pearse Doherty (Donegal, Sinn Fein)
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The Minister says the primary change in the agreement is the anti-avoidance issues. In particular, the new double taxation agreement includes the principal purpose test under base erosion and profit shifting, BEPS, under action 6. He goes on to state that the test ensures that any benefits under the double taxation agreement are denied if the main purpose of the arrangement is the avoidance of tax. Is the Minister happy that the test is present in existing double taxation agreements and particularly with reference to the agreement we have with Luxembourg?