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
The OECD published a discussion draft in March 2014 on proposals for addressing perceived abuse of tax treaties. The draft recommended extensive changes to the OECD Model Treaty together with suggested domestic law provisions targeted at treaty abuse or abuse of domestic law where the abuse involves application of treaty benefits. It also proposed a
As indicated in a newspost earlier this week, the BEPS deliverables for the September 2014 deadline have been published on 16 September 2014 and are available on the OECD website. Please find herewith a link to a summary PwC Bulletin in this respect, highlighting the key take-aways of the reports.
The OECD is keeping its word in preparing and delivering on the objectives as they have been set in the BEPS Action Plan. The deliverables for the September 2014 deadline have just been published and are available on the OECD website (link below). The OECD has published 7 reports (Digital Economy, Hybrid Mismatches, Harmful Tax, Treaty Abuse, Intangibles
This OECD report calls for a very significant rewrite of both the OECD Model Tax Convention and the Commentary, including a US-style Limitation of Benefits (LoB) article as well as a main purpose anti-abuse rule. A variety of other anti-abuse measures are also proposed. If the recommendations are widely adopted, they will undoubtedly reduce treaty