The OECD has released a discussion draft which deals with follow-up work mandated by the Report on Action 6 (Prevent the granting of treaty benefits in inappropriate circumstances) of the BEPS Action Plan.
Paragraph 5 of the Report on Action 6 indicated that follow-up work would be done on certain aspects of the Report:
“… it is recognised that further work will be needed with respect to the precise contents of the model provisions and related Commentary included in Section A of this report, in particular the LOB rule. Further work is also needed with respect to the implementation of the minimum standard and with respect to the policy considerations relevant to treaty entitlement of collective investment vehicles (CIVs) and non-CIV funds. The model provisions and related Commentary included in Section A of this report should therefore be considered as drafts that are subject to improvement before their final version is released in September 2015…”
The discussion draft deals with the follow-up work related to the contents of the model provisions and related Commentary included in Section A of the Report, in particular the LOB rule, as well as with issues related to the treaty entitlement of collective investment vehicles (CIVs) and non-CIV funds (the result of the discussions on how countries intend to implement the minimum standard described in the Report will be included in the revised version of the report that will be released in 2015).
COMMENTS are due by 9 January 2015.
[LTN 227, 24/14]