The Resource BEPS Action 4 and its compatibility with the principle of non-discrimination under article 24(4) of the OECD Model Convention

BEPS Action 4 and its compatibility with the principle of non-discrimination under article 24(4) of the OECD Model Convention

Label
BEPS Action 4 and its compatibility with the principle of non-discrimination under article 24(4) of the OECD Model Convention
Title
BEPS Action 4 and its compatibility with the principle of non-discrimination under article 24(4) of the OECD Model Convention
Creator
Subject
Language
eng
Summary
The final reports of the OECD Base Erosion and Profit Splitting (BEPS) Project were published in October 2015. The OECD's recommendations include an approach to address the risks of base erosion and profit shifting caused by the deduction of interest and other financial payments, namely by implementing a fixed ratio rule, which can be complemented by a group ratio rule. The implementation of the BEPS Action 4 recommended approach could lead to certain issues related to its compatibility with domestic law and with tax treaty obligations. This article addresses one of these issues by analysing the compliance of the BEPS Action 4 recommended approach with tax treaty obligations, mainly with the principle of nondiscrimination under Article 24(4) of the OECD Model Convention
Citation source
In: Intertax. - Alphen aan den Rijn. - Vol. 47 (2019), no. 1 ; p. 55-65
http://library.link/vocab/creatorName
Burkhalter-Martinez, N
Geographic coverage
International
Language note
English
http://library.link/vocab/subjectName
  • interest deduction
  • fixed ratio rule
  • group ratio rule
  • BEPS Project (OECD)
  • tax treaty
  • non-discrimination
Label
BEPS Action 4 and its compatibility with the principle of non-discrimination under article 24(4) of the OECD Model Convention
Instantiates
Publication
Label
BEPS Action 4 and its compatibility with the principle of non-discrimination under article 24(4) of the OECD Model Convention
Publication

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