On Friday, 22 May 2015, the OECD issued a Revised Discussion Draft on BEPS Action 6: Prevention of Treaty Abuse (the RDD).
The RDD includes a simplified Limitation on Benefits (LOB) Article for inclusion in the OECD Model Income Tax Convention and provides ‘conclusions and proposals’ on 20 targeted issues. Most of the proposals are in response to public comment, but the RDD also contains new proposals. Some of them aim to restrict access to treaty benefits with respect to income that may be subject to preferential tax treatment.
The RDD and public comments will be considered at a Working Party meeting on 22 – 26 June 2015. Comments must be submitted by 17 June 2015.
The introduction to the RDD stresses that it does not reflect a consensus view of the Committee on Fiscal Affairs; rather, it is intended to provide stakeholders with substantive proposals on how to address the issues for analysis and public comment.
The PwC newsflash with respect to the revised discussion draft on Action 6 can be found here.