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BEPS Action 6

Prevent treaty abuse

Description of this action in OECD's Action Plan (July 2013)

Develop model treaty provisions and recommendations regarding the design of domestic rules to prevent the granting of treaty benefits in inappropriate circumstances. Work will also be done to clarify that tax treaties are not intended to be used to generate double non-taxation and to identify the tax policy considerations that, in general, countries should consider before deciding to enter into a tax treaty with another country. The work will be co-ordinated with the work on hybrids.

Expected output and deadline for this action in OECD's Action Plan (July 2013)

Expected output 1: Changes to the Model Tax Convention
Deadline: September 2014

Expected output 2: Recommendations regarding the design of domestic rules
Deadline : September 2014

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