The Resource Comments received on public discussion draft : BEPS Action 6 - examples on treaty entitlement of non-CIV funds, 3 February 2017

Comments received on public discussion draft : BEPS Action 6 - examples on treaty entitlement of non-CIV funds, 3 February 2017

Label
Comments received on public discussion draft : BEPS Action 6 - examples on treaty entitlement of non-CIV funds, 3 February 2017
Title
Comments received on public discussion draft : BEPS Action 6 - examples on treaty entitlement of non-CIV funds, 3 February 2017
Subject
Language
eng
Summary
This paper comments on the Public Discussion Draft "BEPS Action 6: Discussion Draft on non-CIV examples", released 6 January 2017. It recommends that the OECD includes examples in the Commentary on the Principal Purpose Test (PPT) rule. Some aspects of the examples should be clarified to further reduce the potential uncertainty on the application of the PPT rule. It sets out suggested refinements to the proposed "regional investment platform example" and the "immovable property non-CIV fund example"
Language note
English
http://library.link/vocab/subjectName
  • principal purpose test
  • BEPS Action Plan
  • treaty abuse
  • investment fund
  • LoB
Label
Comments received on public discussion draft : BEPS Action 6 - examples on treaty entitlement of non-CIV funds, 3 February 2017
Instantiates
Publication
Extent
194 p.
Label
Comments received on public discussion draft : BEPS Action 6 - examples on treaty entitlement of non-CIV funds, 3 February 2017
Publication
Extent
194 p.

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