OECD/G20 Base Erosion and Profit Shifting Project

English
ISSN: 
2313-2612 (online)
ISSN: 
2313-2604 (print)
DOI: 
10.1787/23132612
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Addressing base erosion and profit shifting is a key priority of governments around the globe. In 2013, OECD and G20 countries, working together on an equal footing, adopted a 15-point Action Plan to address BEPS. Beyond securing revenues by realigning taxation with economic activities and value creation, the OECD/G20 BEPS Project aims to create a single set of consensus-based international tax rules to address BEPS, and hence to protect tax bases while offering increased certainty and predictability to taxpayers. A key focus of this work is to eliminate double non-taxation. However in doing so, new rules should not result in double taxation, unwarranted compliance burdens or restrictions to legitimate cross-border activity.

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Preventing the Granting of Treaty Benefits in Inappropriate Circumstances, Action 6 - 2015 Final Report

Preventing the Granting of Treaty Benefits in Inappropriate Circumstances, Action 6 - 2015 Final Report You or your institution have access to this content

English
Click to Access: 
    http://oecd.metastore.ingenta.com/content/2315331e.pdf
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Author(s):
OECD
05 Oct 2015
Pages:
104
ISBN:
9789264241695 (PDF) ;9789264241206(print)
DOI: 
10.1787/9789264241695-en

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This report includes changes to the OECD Model Tax Convention to prevent treaty abuse. It first addresses treaty shopping through alternative provisions that form part of a minimum standard that all countries participating in the BEPS Project have agreed to implement.  It also includes specific treaty rules to address other forms of treaty abuse and ensures that tax treaties do not inadvertently prevent the application of domestic anti-abuse rules. The report finally includes changes to the OECD Model Tax Convention that clarify that tax treaties are not intended to create opportunities for non-taxation or reduced taxation through tax evasion or avoidance (including through treaty-shopping) and that identify the tax policy considerations that countries should consider before deciding to enter into a tax treaty with another country.

Also available in Spanish
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Table of Contents

Introduction

A. Treaty provisions and/or domestic rules to prevent the granting of treaty benefits in inappropriate circumstances

B. Clarification that tax treaties are not intended to be used to generate double non-taxation

C. Tax policy considerations that, in general, countries should consider before deciding to enter into a tax treaty with another country

 
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