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Prevention of Tax Treaty Abuse – Third Peer Review Report on Treaty Shopping

Inclusive Framework on BEPS: Action 6

image of Prevention of Tax Treaty Abuse – Third Peer Review Report on Treaty Shopping

The BEPS Action 6 minimum standard on preventing the granting of treaty benefits in inappropriate circumstances, is one of the four BEPS minimum standards that all members of the OECD/G20 Inclusive Framework on BEPS (Inclusive Framework) have committed to implement. This report reflects the outcome of the third peer review of the implementation of the Action 6 minimum standard on treaty shopping as approved by the Inclusive Framework. It includes the aggregate results of the review and data on tax treaties concluded by each of the 137 members of the Inclusive Framework on 30 June 2020 and it contains the jurisdictional section for each member. The data compiled for this peer review demonstrate that the MLI has been the tool used by the vast majority of jurisdictions that have begun to implement the minimum standard and that the MLI has started to impact tax treaties of jurisdictions that have ratified it.

English Also available in: French

Difficulties in implementing the minimum standard

The peer review also provides jurisdictions that encounter difficulties in reaching agreement with another jurisdiction to implement the Action 6 minimum standard with an opportunity to raise concerns in writing to the OECD Secretariat. This process, which is set out in paragraph 19 of the Peer Review Documents, was put in place to identify cases where a jurisdiction is facing a treaty partner that is a member of the Inclusive Framework that is unwilling to respect its commitment to implement the minimum standard.

English Also available in: French

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