Overview Action Title Published Deadline 7 Prevent the artificial avoidance of PE Status 31 October 2014 9 January 2015 10 Transfer Pricing: Low value-adding services 3 November 2014 14 January 2015 6 Prevent treaty abuse (follow-up work) 21 November 2014 9 January 2015 10 Transfer Pricing: Profit splits 16 December 2014 6 February 2015 10 Transfer Pricing: Commodity transactions 16 December

The report is divided into four chapters: 1. Context of the Action 6 Minimum Standard. 2. Conducting the Action 6 Peer Review on Treaty Shopping. 3. Aggregate results of the Peer Review.

This Action has produced multiple alternatives to afford Contracting States flexibility but at the same time ensuring that the common goal of implementing safeguards within the treaty against treaty abuse is achieved. 2019-07-04 In our previous post published on 6 December 2016 we described the OECD’s BEPS Project in the context of the publishing of the draft Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (the “Convention”).. One area that the OECD has itself acknowledged requires further consideration is in relation to BEPS Action 6, the final report The BEPS Action Plan contains 15 Actions. There is an obligation to implement (minimum standards) with regard to combating harmful tax practices and the spontaneous exchange of information on advance tax rulings (Action 5), the inclusion of abuse clauses in double taxation agreements (Action 6), country-by-country reporting (Action 13) and the dispute resolution mechanisms (Action 14). Article 6 contains the proposal described in the Action 6 final report to change the preamble language of a CTA. This is to ensure compliance with one of the requirements of the minimum standard of expressing the common intention to eliminate double taxation without creating opportunities for non-taxation or reduced taxation through tax evasion or avoidance, including through 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. Action to fight corporate tax avoidance has been deemed necessary in the OECD forum has and received further impetus through the G20/OECD Base e rosion and p rofit shifting action plan (known as BEPS). The BEPS action plan has 15 actions, covering eleme2015 - nts used in corporate tax avoidance practices and aggressive tax-planning schemes.

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.

In July 2013, the OECD published an Action Plan on Base Erosion and Profit Shifting (BEPS). This set out 15 BEPS actions, and on 5 October 2015 the OECD and G20 published final reports along with an explanatory statement outlining consensus recommendations that had been reached as part of the BEPS project. BEPS Action 6: Preventing the granting of treaty benefits in inappropriate circumstances On 22 May 2015 the OECD, as part of its work on the Action Plan to address Base Erosion and Profit Shifting (‘BEPS’), released a Revised Discussion Draft on Action 6 in relation to preventing the granting of treaty benefits in inappropriate circumstances. Preventing the Granting of Treaty Benefits in Inappropriate Circumstances, Action 6 - 2015 Final Report This report includes changes to the OECD Model Tax Convention to prevent treaty abuse.

One area that the OECD has itself acknowledged requires further consideration is in relation to BEPS Action 6, the final report on which was published in October 2015, which seeks to prevent access to treaty benefits in inappropriate circumstances (“treaty shopping”).

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The draft for Article X, ‘‘Entitlement to Benefits,’’ the first five paragraphs of which are described therein as ‘‘specific antiabuse rule aimed at treaty group action is more complex and takes time to work out. Such is the case with the OECD’s approach to non-collective investment vehicle funds (non-CIV funds) and their interaction with the BEPS Action 6 on preventing the granting of treaty benefits in inappropriate circumstances. Action 6 refresher Action 6 of the BEPS Action Plan identified treaty abuse, and in particular treaty shopping, as one of the most important sources of BEPS concerns.
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customs and trade facilitation action. on the review of BEPS Action 14: Making Dispute Resolution Mechanisms More Effective VISITOR_INFO1_LIVE, 1, 6 months, This cookie is set by Youtube. 6.

Action 6 of the OECD/G20 Base Erosion and Profit Shifting (BEPS) Project identifies treaty abuse, and in particular treaty shopping, as one of the most important sources of BEPS concerns. Taxpayers engaged in treaty shopping and other treaty abuse strategies undermine tax Action 6 aims to prevent treaty abuse by developing model treaty provisions to prevent the granting of treaty benefits in inappropriate circumstances. A final report on Action 6 was released by the OECD as part of its 5 October 2015 package of final reports.
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BEPS Action 6: Preventing the granting of treaty benefits in inappropriate circumstances On 16 September 2014, ahead of the G20 Finance Ministers’ meeting on 20-21 September, the OECD published seven papers as a first tranche of deliverables under the Base Erosion and Profit Shifting (‘BEPS’) Project. The

In this respect, the PPT provision proposed under BEPS Action 6 is not an exception. 2020-08-17 2020-08-13 BEPS Actions. In July 2013, the OECD published an Action Plan on Base Erosion and Profit Shifting (BEPS).

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Jul 4, 2019 This is a serie of three blogposts regarding the Principal Purpose Test (PPT) of BEPS Action 6. The first blogpost addresses PPT and MLI, the

It first addresses treaty shopping through alternative provisions that form part of a minimum standard that all countries participating in the BEPS Project have agreed to implement. It also includes specific treaty rules to address other forms of treaty abuse and ensures that tax treaties do not Action 6 (Treaty Abuse) is a key element of the OECD's BEPS Project. Action 6 targets, in summary, "treaty shopping", i.e., where a person in country A, which is not, in principle, eligible to benefit from a given tax treaty with country B, invests through an entity in country C to benefit from the treaty. In BEPS Action 6 an approach is recommended to address treaty shopping situations-First, a clear statement that the Contracting States, when entering into a treaty, wish to prevent tax avoidance and, in particular, intend to avoid creating opportunities for treaty shopping will be included in tax treaties. BEPS Action 6 - An inclusion of anti-abuse measures in tax treaties to prevent the improper use of a tax treaty - Are the measures suggested in BEPS Action 6 necessary from a Swedish perspective? Fridh, Johanna LU HARN60 20161 Department of Business Law. Mark; Abstract First Action 6 peer review report. On 14 February 2019, the OECD released the first peer review report on BEPS Action 6 prevention of treaty abuse.