The OECD has released a discussion draft document that includes the proposals produced with respect to Action 6 (Prevent Treaty Abuse) of its BEPS (Base Erosion and Profit Shifting) Action Plan. Interested parties have been invited to send comments on this discussion draft, which includes the preliminary results of the work carried out in the 3 different areas identified in Action 6:

  • Develop model treaty provisions and recommendations regarding the design of domestic rules to prevent the granting of treaty benefits in inappropriate circumstances.
  • Clarify that tax treaties are not intended to be used to generate double non-taxation.
  • Identify the tax policy considerations that, in general, countries should consider before deciding to enter into a tax treaty with another country.

COMMENTS should be sent to the OECD by 9 April 2014 at the latest.

[LTN 51, 17/3/14]