Prevention of Treaty Abuse – Second Peer Review Report on Treaty Shopping

Inclusive Framework on BEPS: Action 6

image of Prevention of Treaty Abuse – Second 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 second 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 129 members of the Inclusive Framework on 30 June 2019 and it contains the jurisdictional section for each member (see Annex 2). 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’s impact is expected to increase quickly as jurisdictions ratify it.

English Also available in: French


Denmark has 70 tax agreements in force, as reported in its response to the Peer Review questionnaire, including the multilateral Nordic Convention concluded with Finland, Iceland, Norway and Sweden (the “Nordic Convention”). See the Multilateral convention concluded by Denmark, Finland, the Faroe Islands, Iceland, Norway and Sweden: for the avoidance of double taxation with respect to taxes on income and on capital (1996, 1997, and 2008). In total, Denmark identified 73 "agreements" in its List of Tax agreements: 69 bilateral agreements and the Nordic Convention concluded with four of its treaty partners. Two of its agreements, the agreements with Japan and the Netherlands, comply with the minimum standard.

English Also available in: French

This is a required field
Please enter a valid email address
Approval was a Success
Invalid data
An Error Occurred
Approval was partially successful, following selected items could not be processed due to error