Action 6 The OECD proposal provides a three-pronged approach: Treaty statement re: anti-avoidance rule and treaty shopping opportunities; Specific anti-abuse rule based on Limitation of Benefit The BEPS Action Plan states that “Treaty abuse is one of the most important sources of BEPS concerns”, and then describes Action 6 as recommended the following “three-pronged approach”: 2015-10-05 BEPS Action 14: Make Dispute Resolution Mechanisms More Effective The Organization for Economic Cooperation and Development on December 18, 2014, must be read in the broader context of the intention to introduce a three-pronged approach designed to represent a step change in the resolution of treaty-related disputes through the MAP. Corporate/International tax–Actions1to7and11, 12,14and15. 6. ActionPlan1–DigitalEconomy Action 1: Addressing the tax challenges of the Digital Economy (‘DE’) • No special tax regime has been prescribed. BEPS measures under other Action Plans seek to address these challenges. • Destination based tax for GST / VAT Indian perspective Impact of BEPS Implementation - there was a fairly broad consensus that 1) the Action 1 VAT recommendations are being widely implemented and that they are having a significant impact on tax collection in market jurisdictions; 2) the BEPS changes are impacting business models (particularly Action 7 encouraging a shift towards buy/sell), and that consistency in business model globally was The MLI also implements the BEPS Action 6 minimum standard by implementing a principal purpose test (PPT). Under the PPT rule, a tax treaty benefit is denied where one of the principal purposes of an arrangement or transaction is to directly or indirectly obtain the benefit, unless the granting of that benefit in the circumstances would be in accordance with the object and purpose of the See EY Global Tax Alert, OECD releases final reports on BEPS Action Plan, dated 6 October 2015. See EY Global Tax Alert, OECD releases peer review documents on BEPS Action 5 on Harmful Tax Practices and on BEPS Action 13 on Country-by-Country Reporting, dated 6 February 2017.

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It also includes specific rules and recommendations to address other forms of treaty abuse. The basic framework of Action 6 is based on a three-pronged approach to be used by countries to release new treaties or to modify existing ones: (1) a clear statement that the Contracting States wish to prevent tax avoidance and creation of opportunities for treaty shopping; (2) a specific anti-abuse rule derived from the U.S. experience (LOB); 6. We believe that the threepronged approach will be unnecessarily burdensome. The - layers of rules that need to be assessed; the complexity of those rules; potential interpretations and different applications by States in practice, give rise to an increased administrative burden, and uncertainty. We do understand and support the idea that Report of the work of the OECD/G20 on the BEPS action 6 ―Preventing the granting of Treaty Benefits in Inappropriate Circumstances‖ where OECD proposed the three-pronged approach on preventing treaty abuse. 5 The first recommendation regards the inclusion in the tax treaties of a BEPS Action 6 INTRODUCTION 1.

Action 6 – Treaty abuse • Treaty abuse is one of the most important sources of BEPS concerns • Three pronged approach to deal with Treaty shopping − A statement that Treaties intend to avoid tax evasion / avoidance / Treaty shopping (minimum standard); and − Inclusion of LOB rule in Treaties; and / or Just to reiterate the treaty abuse measures, the Action 6 of BEPS plan specifically addresses the concerns of treaty abuse and the ways for prevention of such abuse and makes suggestion of a three-pronged approach to address a treaty shopping situation. The PPT, the BEPS Inclusive Framework and MLI. 1. Background .

See EY Global Tax Alert, OECD releases peer review documents on BEPS Action 5 on Harmful Tax Practices and on BEPS Action 13 on Country-by-Country Reporting, dated 6 February 2017. 3.

Minimum standards are the BEPS recommendations that all members of the Inclusive Framework are committed to implement. These are some of the recommendations included in Action 5 on harmful tax practices, Action 6 on treaty abuse, Action 13 on transfer pricing documentation and CbCR and Action 14 on dispute resolution. The MLI also implements the BEPS Action 6 minimum standard by implementing a principal purpose test (PPT).

2014-12-26 United Kingdom: BEPS Actions implementation Last updated: May 2017 More information on the Global Tax Reset & BEPS >>> Back to BEPS Actions >>> Interest deductions (Action 4) Common approach Following public consultation, draft legislation restricting corporate interest tax deductibility was issued in … 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.
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8 Published in Government Gazette No. 185553 of 15/12/1997. Action 6 - Treaty Benefits Action 6 identifies treaty abuse, and in particular treaty shopping as one of the most important sources of BEPS concerns. The report suggests that the following three pronged approach be taken to tackle treaty abuse: 1) First, a clear statement in tax treaties that the Contracting States, when entering into a treaty, All rights reserved. 25 OECD – BEPS 2014 Preventing the granting of treaty benefits in inappropriate circumstances Treaty abuse and treaty shopping identified as one of the most important sources of BEPS concerns Three pronged approach recommended to address treaty abuse and shopping arrangements Design rules to prevent granting of treaty benefits in inappropriate circumstances Tax treaties not intended to be used to generate double non-taxation Identification of tax policy consideration Action 14 contains one of only four minimum standards implemented by the BEPS project, on which competent authorities will be externally monitored. This reaffirms the importance of MAP as a principle, both at a treaty level, and in ensuring greater clarity for taxpayers and fellow competent authorities on how each country provides access to MAP and what MAP procedures exist. Action 6 : Prevent treaty abuse One of the key actions in preventing BEPS is Action 6, Preventing Treaty Abuse which includes combatting treaty shopping. The output is to recommend changes to the Model Tax Convention and recommendations for the design of domestic rules to prevent unintended uses of tax treaties such as group action is more complex and takes time to work out.

introduction of the principal purposes test under BEPS Action 6 on preventing treaty abuse. - using the combined LOB and PPT approach described above; or - the inclusion of the PPT rule or; 3 OECD/G20 Base Erosion and Profit Shifting Project “Preventing the Granting of Treaty Benefits in Inappropriate Circumstances Action 6: 2015 Final Report (2015) in para 15. 4 OECD/G20 2015 Final Report on Action 6 in para 19. The OECD published an Action Plan, which includes 15 action points to address BEPS in a comprehensive manner and sets deadlines to implement these actions. Action Point 6 of the Action Plan aims to prevent the abuse of double taxation agreements ( DTA ) and to develop model DTA provisions and recommendations regarding the design of domestic rules to prevent the granting of DTA benefits … Action 6 . Prevent . treaty abuse .
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Prevention of tax treaty abuse. Minimum Standard. BEPS Action 6 addresses treaty shopping through treaty provisions whose adoption forms part of a minimum standard that members of the BEPS Inclusive Framework have agreed to implement. It also includes specific rules and recommendations to address other forms of treaty abuse. The basic framework of Action 6 is based on a three-pronged approach to be used by countries to release new treaties or to modify existing ones: (1) a clear statement that the Contracting States wish to prevent tax avoidance and creation of opportunities for treaty shopping; (2) a specific anti-abuse rule derived from the U.S. experience (LOB); 6.

• Destination based tax for GST / VAT Indian perspective Impact of BEPS Implementation - there was a fairly broad consensus that 1) the Action 1 VAT recommendations are being widely implemented and that they are having a significant impact on tax collection in market jurisdictions; 2) the BEPS changes are impacting business models (particularly Action 7 encouraging a shift towards buy/sell), and that consistency in business model globally was The MLI also implements the BEPS Action 6 minimum standard by implementing a principal purpose test (PPT).
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Alternatively, it suggests that countries notify treaty partners of circumstances where access to MAP is denied. in July 2013. The BEPS Action Plan identified fifteen actions to address base erosion and profit shifting in a comprehensive manner and set deadlines to implement these actions.