Preventing The Granting Of Treaty Benefits In Inappropriate Circumstances PDF Download
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| Author | : Oecd |
| Publisher | : OCDE |
| Total Pages | : 107 |
| Release | : 2014-09-16 |
| Genre | : Business & Economics |
| ISBN | : 9789264219069 |
Download Preventing the Granting of Treaty Benefits in Inappropriate Circumstances Book in PDF, ePub and Kindle
This report includes proposed changes to the OECD Model Tax Convention to prevent treaty abuse. Countries participating in the BEPS Project have agreed on a minimum standard to prevent treaty shopping and other strategies aimed at obtaining inappropriately the benefit of certain provisions of tax treaties. The report also ensures that tax treaties do not inadvertently prevent the application of legitimate domestic anti-abuse rules. The report clarifies that tax treaties are not intended to be used to generate double non-taxation and identifies the tax policy considerations that countries should consider before deciding to enter into a tax treaty with another country. The model provisions included in the report provide intermediary guidance as additional work is needed, in particular in relation to the limitation on benefits rule.
| Author | : OECD |
| Publisher | : Org. for Economic Cooperation & Development |
| Total Pages | : 102 |
| Release | : 2015-10-21 |
| Genre | : |
| ISBN | : 9789264241206 |
Download OECD/G20 Base Erosion and Profit Shifting Project Preventing the Granting of Treaty Benefits in Inappropriate Circumstances, Action 6 - 2015 Final Report Book in PDF, ePub and Kindle
This report includes changes to the OECD Model Tax Convention to prevent treaty abuse. 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 inadvertently prevent the application of domestic anti-abuse rules. The report finally includes changes to the OECD Model Tax Convention that clarify that tax treaties are not intended to create opportunities for non-taxation or reduced taxation through tax evasion or avoidance (including through treaty-shopping) and that identify the tax policy considerations that countries should consider before deciding to enter into a tax treaty with another country.
| Author | : F. Alimandi |
| Publisher | : |
| Total Pages | : |
| Release | : 2016 |
| Genre | : |
| ISBN | : |
Download BEPS Action 6 : Preventing the Granting of Treaty Benefits in Inappropriate Circumstances Book in PDF, ePub and Kindle
The OECD base erosion and profit shifting (BEPS) project Action 6 identifies tax treaty abuse and, in particular, treaty shopping, as one of the most significant sources of BEPS concerns.
| Author | : OECD |
| Publisher | : OECD Publishing |
| Total Pages | : 112 |
| Release | : 2014-09-16 |
| Genre | : |
| ISBN | : 9264219129 |
Download OECD/G20 Base Erosion and Profit Shifting Project Preventing the Granting of Treaty Benefits in Inappropriate Circumstances Book in PDF, ePub and Kindle
This report from the OECD/G20 Base Erosion and Profit Shifting project examines the issue of preventing the granting of treaty benefits in inappropriate circumstances. It includes proposed changes to the OECD Model Tax convention and summarises progress to date.
| Author | : |
| Publisher | : |
| Total Pages | : 298 |
| Release | : 2021 |
| Genre | : Double taxation |
| ISBN | : 9789264356108 |
Download Prevention of Tax Treaty Abuse - Third Peer Review Report on Treaty Shopping Book in PDF, ePub and Kindle
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.
| Author | : OECD |
| Publisher | : OECD Publishing |
| Total Pages | : 106 |
| Release | : 2015-10-05 |
| Genre | : |
| ISBN | : 9264241698 |
Download OECD/G20 Base Erosion and Profit Shifting Project Preventing the Granting of Treaty Benefits in Inappropriate Circumstances, Action 6 - 2015 Final Report Book in PDF, ePub and Kindle
Addressing base erosion and profit shifting (BEPS) is a key priority of governments. In 2013, OECD and G20 countries, working together on an equal footing, adopted a 15-point Action Plan to address BEPS. This publication is the final report for Action 6.
| Author | : |
| Publisher | : |
| Total Pages | : 298 |
| Release | : 2021 |
| Genre | : Double taxation |
| ISBN | : 9789264579729 |
Download Prevention of Tax Treaty Abuse - Third Peer Review Report on Treaty Shopping Book in PDF, ePub and Kindle
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.
| Author | : OECD |
| Publisher | : OECD Publishing |
| Total Pages | : 302 |
| Release | : 2021-04-01 |
| Genre | : |
| ISBN | : 9264950982 |
Download OECD/G20 Base Erosion and Profit Shifting Project Prevention of Tax Treaty Abuse – Third Peer Review Report on Treaty Shopping Inclusive Framework on BEPS: Action 6 Book in PDF, ePub and Kindle
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.
| Author | : OECD |
| Publisher | : OECD Publishing |
| Total Pages | : 75 |
| Release | : 2015-06-29 |
| Genre | : |
| ISBN | : 9264238107 |
Download Preventing the Granting of Treaty Benefits in Inappropriate Circumstances (Chinese version) Book in PDF, ePub and Kindle
| Author | : Vikram Chand |
| Publisher | : |
| Total Pages | : |
| Release | : 2017 |
| Genre | : |
| ISBN | : |
Download BEPS Action 6 - Policy Proposals Book in PDF, ePub and Kindle
In October 2015, the OECD released its final deliverable on Action 6 that is dedicated to prevent the granting of treaty benefits in inappropriate circumstances. In order to determine the most appropriate manner to prevent the granting of treaty benefits, the final deliverable differentiates between two situations. The first situation deals with cases where a taxpayer tries to abuse tax treaty provisions, for example, by engaging in treaty shopping schemes. For such cases, the final deliverable suggests the adoption of treaty anti-abuse rules. The second situation deals with cases where a taxpayer tries to avoid the application of domestic anti-abuse rules (anti-abuse rules which counter treaty abuse as well as domestic law abuse), by arguing that the provisions of tax treaties preclude the application of such rules. For such cases, clarification changes are proposed in the OECD Commentary. The contribution comments on these anti-abuse rules and answers two questions from a policy perspective. Firstly, when countering treaty abuse - should tax authorities resort to treaty anti-abuse or domestic anti-abuse rules? Secondly, how do domestic anti-avoidance rules interact with tax treaties?
