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

Preventing the Granting of Treaty Benefits in Inappropriate Circumstances You or your institution have access to this content

English
Click to Access: 
    http://oecd.metastore.ingenta.com/content/2314281e.pdf
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Author(s):
OECD
16 Sep 2014
Pages:
108
ISBN:
9789264219120 (PDF) ;9789264219069(print)
DOI: 
10.1787/9789264219120-en

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This report includes proposed changes to the OECD Model Tax Convention to prevent treaty abuse. Countries participating in the BEPS Project have agreed on a minimum standard to prevent treaty shopping and other strategies aimed at obtaining inappropriately the benefit of certain provisions of tax treaties. The report also ensures that tax treaties do not inadvertently prevent the application of legitimate domestic anti-abuse rules. The report clarifies that tax treaties are not intended to be used to generate double non-taxation and identifies the tax policy considerations that countries should consider before deciding to enter into a tax treaty with another country. The model provisions included in the report provide intermediary guidance as additional work is needed, in particular in relation to the limitation on benefits rule.

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Table of Contents

Executive summary
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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