Para 71 of the Commentary on Art 24 of the OECD MC has already pointed out that anti-abuse rules might be necessary to curb source tax avoidance in triangular cases where companies had transferred assets such as shares, bonds or patents to their permanent establishments in jurisdictions with preferential tax regimes. Art 10 of the MLI has picked up this problem and contains an anti-abuse provision which, at first sight, is a simple and efficient response to such abusive practices: The source country shall no longer be bound by its treaty with the residence country to grant treaty relief if, for once, the residence country is unable to tax the respective income (e.g. due to a tax treaty with the PE country using the exemption system) and, secondly, if the tax in the PE country is less than 60 % of the tax in the residence country. However, a closer analysis of this provision reveals substantial problems which, in the worst case, may end up in a threefold taxation. In any case, debtor companies in the source country should take precaution against worrisome consequences.