2019-02-15

del 5-6 Novembre 2012, si è tradotto in un manda-to esplicito all'OCSE ad approfondire il tema. Al G20 di Mosca (19-20 luglio 2013) l’Ocse ha pre-sentato il rapporto Action Plan on Base Erosion and Profit Shifting6 individuando un piano d’azione, articolato in 15 misure, volto ad analiz-3 OECD (2015), Measuring and Monitoring BEPS, Action

Analysis - BEPS Action 6 and Private Equity Funds Speed read: Since BEPS Action 6 was introduced, the OECD and the private equity industry have been grappling with how to apply anti-treaty abuse provisions to private equity fund structures. The OECD is concerned that private equity funds may be used by investors to achieve better treaty n a sequel to my earlier summary on BEPS- Action 2 report, I have again attempted to summarize the Action 6 Report – Preventing the Granting of Treaty Benefits in Inappropriate Circumstances. In said report, OCED has proposed to prevent the benefits Preventing the Granting of Treaty Benefits in Inappropriate Circumstances, Action 6 - 2015 Final Report This report includes changes to the OECD Model Tax Convention to prevent treaty abuse. It first addresses treaty shopping through alternative provisions that form part of a minimum standard that all countries participating in the BEPS Project have agreed to implement. Actions providing the terms of reference and the methodology by which the peer reviews would be conducted. On 29 May 2017, the OECD released the peer review documents, (the Terms of Reference and Assessment Methodology (the Methodology) for BEPS Action 6. 3 The terms of reference reiterated that to be in compliance with October 8, 2015.

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2015-06-17 2015-10-05 BEPS MONITORING GROUP Revised Discussion Draft for BEPS Action 6: Prevent Treaty Abuse This response is submitted by the BEPS Monitoring Group (BMG). The BMG is a group of experts on various aspects of international tax, set up by a number of civil society organizations which research and campaign for tax justice including the Global Alliance for BEPS Project including its four minimum standards (Action 5 on harmful tax practices, Action 6 on treaty abuse, Action 13 on country-by-country reporting and Action 14 on dispute resolution mechanisms). They will also be able to monitor the evolution of the tax raised by the digital economy challenges (Action 1) … abuse under BEPS Action 6. This two-part article considers the structure and potential application of the PPT in the context of pre-BEPS responses to perceived tax treaty abuses, the OECD’s work on BEPS Action 6, and other provisions of the MLI including the preamble text in Article 6(1). The first part, in the previous issue of BEPS Action 6 – where do the final proposals leave the asset management industry, securitisations and capital markets SPVs?

548. V. Analysis .

, besökt Action 6 – 2015 Final Report, OECD/G20 Base Erosion and Profit  av K ANDERSSON · Citerat av 3 — Global Issue, OECD 1998, http://www.oecd.org/tax/transparency/44430243.pdf. inspirera tankegångarna bakom de 15 åtgärdsområden som BEPS kommit och bestämde sig för att betala 20 miljoner pund extra i skatt.6 I vilken mån Base Erosion Involving Interest Deductions and Other Financial Payments, Action.

Revised Discussion Draft: BEPS Action 6: Prevent Treaty Abuse (OECD Publishing 2015). 5 OECD, Preventing the Granting of Treaty Benefits in Inappropriate Circumstances, Action 6 – 2015 Final Report (OECD Publishing 2105). References are made to paras of the Report, and paras of the proposed Commentary to the PPT. 6 The Report (n 5) 5. 7 Ibid 6.

It first addresses treaty shopping through alternative provisions that form part of a minimum standard that all countries participating in the BEPS Project have agreed to implement. Actions providing the terms of reference and the methodology by which the peer reviews would be conducted. On 29 May 2017, the OECD released the peer review documents, (the Terms of Reference and Assessment Methodology (the Methodology) for BEPS Action 6. 3 The terms of reference reiterated that to be in compliance with October 8, 2015. BEPS Action 6 identifies tax treaty abuse and, in particular, treaty shopping, as one of the most significant sources of BEPS concerns. II. Generic Framework From a first reading of Action 6 it is possible to become lost in the complex package designed to prevent treaty abuse.

Countries that do not have anti-abuse provisions in their tax treaties are exposed to lower tax revenues.
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On 19 July 2013, the OECD published its Action Plan on Base Erosion and Profit Shifting (“BEPS”) that provides for 15 actions. The BEPS Action Plan identifies treaty abuse and in particular treaty shop-ping as one of the most important sources for BEPS concerns. Action 6 of the BEPS Action Plan (Preventing Treaty Abuse) aims at the following the OECD Base Erosion and Profit Shifting (BEPS) initiative, with special regard for the proposed general anti-abuse rule (GAAR). In the author’s opinion, although some of the criticism raised against it is justified, the proposed rule is in line with similar rules in comparative law.

6 Genomförande av regler för att neutralisera effekterna av hybrida 1 OECD (2015), Measuring and Monitoring BEPS, Action 11 – 2015 Final  Den multilaterala konvention som beretts inom ramen för OECD och som medför av konventionen: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
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Action 6 of the OECD/G20 Base Erosion and Profit Shifting (BEPS) Project identifies treaty abuse, and in particular treaty shopping, as one of the most important sources of BEPS concerns. Taxpayers engaged in treaty shopping and other treaty abuse strategies undermine tax

SonoVue (svavelhexafluorid). Utbildningsmaterial (pdf)  BEPS Action 6: Preventing the granting of treaty benefits in inappropriate circumstances On 22 May 2015 the OECD, as part of its work on the Action Plan to address Base Erosion and Profit Shifting (‘BEPS’), released a Revised Discussion Draft on Action 6 in relation to preventing the granting of treaty benefits in inappropriate circumstances. BEPS Action 6: Preventing the granting of treaty benefits in inappropriate circumstances On 16 September 2014, ahead of the G20 Finance Ministers’ meeting on 20-21 September, the OECD published seven papers as a first tranche of deliverables under the Base Erosion and Profit Shifting (‘BEPS’) Project. The The BEPS Action Plan includes 15 actions to address BEPS in a comprehensive manner and sets deadlines to implement these actions. 2. The Action Plan identifies treaty abuse, and in particular treaty shopping, as one of the most important sources of BEPS concerns. Action 6 (Prevent Treaty Abuse) describes the work to be undertaken in this area.

Action Plan on Base Erosion and Profit Shifting (BEPS) adopted by the G20 in 2013. i. The two- Action 11 on measuring the BEPS impact (report): the 6 OECD indicators could be very http://www.oecd.org/tax/transparency/ 44430243.pdf

Taxpayers engaged in treaty shopping and other treaty abuse strategies undermine tax BEPS Action 6: Preventing the granting of treaty benefits in inappropriate circumstances On 22 May 2015 the OECD, as part of its work on the Action Plan to address Base Erosion and Profit Shifting (‘BEPS’), released a Revised Discussion Draft on Action 6 in relation to preventing the granting of treaty benefits in inappropriate circumstances. In September 2015, the OECD released the final report on BEPS action 6. The main purpose of the action 6 is the prevention of ―granting treaty benefits in inappropriate circumstances‖. Regarding the prevention of treaty abuse the OECD presented three main recommendations. These actions are only proposals and therefore they constitute soft law. n a sequel to my earlier summary on BEPS- Action 2 report, I have again attempted to summarize the Action 6 Report – Preventing the Granting of Treaty Benefits in Inappropriate Circumstances.

It first addresses treaty shopping through alternative provisions that form part of a minimum standard that all countries participating in the BEPS Project have agreed to implement.