The Resource BEPS Action 6 : tax treaty abuse

BEPS Action 6 : tax treaty abuse

BEPS Action 6 : tax treaty abuse
BEPS Action 6 : tax treaty abuse
Action 6 of the base erosion and profit shifting (BEPS) Action Plan identified treaty abuse, and in particular treaty shopping, as one of the most important sources of BEPS concerns. In September 2014 the OECD has issued the deliverable for action 6 that consists of three parts: (1) development of model treaty provisions and recommendations regarding the design of domestic rules to prevent the granting of treaty benefits in inappropriate circumstances, (2) clarification that tax treaties are not intended to be used to generate double non-taxation, and (3) identification of tax policy considerations that countries should consider before entering into tax treaties. This article critically analyses the OECD's output on action 6. [This article comments on BEPS-Action point 6 - Second Report of 2014]
Citation source
In: Intertax. - Alphen aan den Rijn. - Vol. 43 (2015),
  • De Broe, L
  • Luts, J
Language note
  • BEPS Action Plan
  • treaty abuse
  • OECD Model Commentaries
  • double non-taxation
  • LoB
  • saving clause
  • exit tax
  • tax policy
BEPS Action 6 : tax treaty abuse

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