- using the combined LOB and PPT approach described above; or - the inclusion of the PPT rule or; 3 OECD/G20 Base Erosion and Profit Shifting Project “Preventing the Granting of Treaty Benefits in Inappropriate Circumstances Action 6: 2015 Final Report (2015) in para 15. 4 OECD/G20 2015 Final Report on Action 6 in para 19.

Action 6 of the BEPS Action Plan (Preventing Treaty Abuse) aims at the following three areas: 1. Development of model treaty provisions and The Discussion Draft recommends a three-pronged approach to address situations of treaty shopping: a) Clarify in the title and the preamble of tax treaties

b) Include in tax treaties a LOB provision based on The Action Plan on Base Erosion and Profit Shifting (“BEPS Action Plan”) identified 15 actions to address BEPS in a comprehensive manner. In October 2015, the G20 Finance Ministers endorsed the BEPS Package, which includes the report on Action 6: Preventing the Granting of Treaty Benefits in Inappropriate Circumstances (“the Report on Action 6” or “the Report”, OECD (2015)). 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 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 1.1 Action 6: ‘minimum standard’ against treaty shopping The base erosion and profit shifting (‘BEPS’) initiative was launched on July 19, 2013, when the Organization for Economic Cooperation and Development (‘OECD’) presented Action Plan on BEPS1 endorsed by G20 The OECD final report on action 6 recommends a three-pronged approach to address treaty shopping:3 1) a clear statement in the title and preamble of a DTA that the contracting parties intend to avoid creating opportunities for nontaxation or reduced taxation through tax evasion or avoidance; 2017-03-09 · BEPS Action Point 6: Prevent treaty abuse.

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Although recommending this “three-pronged approach” to tax treaty shopping, the Final Report of BEPS Action 6  initially introduced, was to implement the expected outcome of BEPS Action 6. reporting system based on the three-tiered approach introduced in the 2016 tax  14 Mar 2014 Action 6 (Prevent Treaty Abuse) describes the work to be undertaken that the following three-pronged approach be used to address treaty  14 Jul 2014 In July 2013 the OECD released its “BEPS Action Plan”, which 15 actions points, one of which is “Action 6 – Prevent Treaty Abuse”. In particular, the discussion draft recommended the following “three-pronged approa 23 Jul 1992 Action 6 report, is that Finance will propose draft domestic anti-treaty- also conflict with the OECD public discussion draft on BEPs Action 6.9 within case 1 .72 The Action 6 report recommends a three-pronged appro 16 Sep 2014 The remaining eight BEPS Action Plan deliverables are due in 2015. Action 6 in the BEPS Action Plan had identified treaty abuse, and in The new Chapter V provides for a three-tiered approach to transfer pricing&nbs This legal update discusses the BEPS proposals and identifies action items and of Treaty Benefits in Inappropriate Circumstances – Action 6 (the Action 6 Final The Revised Guidelines also adopt a three-tiered standardized approach 15 Feb 2019 OECD releases first annual peer review report on BEPS Action 6 tax evasion or avoidance, and one of three methods of addressing treaty shopping. standards to reinforced international standards, common approaches to 5 Oct 2015 Although the reports have been billed as the 'final' BEPS reports and shopping (Action Point 6), Country-by-Country Reporting (Action 13),  26 Nov 2015 Session 6 of 8 part OECD BEPS seriesSign up for upcoming live project outcomes Part 6: Anti-abuse Measures under Actions 3, 5, 6 and 12. BEPS is a tax planning strategies that eploits tax and mismatches rules to make profit disappear and shift profits BEPS Action plan -6 Preventing treaty abuse: – BEPS Action plan -13 Three tier standardized approach to transfer pr Action 11 on measuring the BEPS impact (report): the 6 OECD indicators could profit split method and hard to value intangibles, rules for the attribution of average ratio for all other countries, increasing three-fold between 2009 Action 6: Preventing the granting of treaty benefits in inappropriate circumstances .

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.

It came into force in July 2018. Many tax havens opted out from several of the Actions, including Action 12 (Disclosure of aggressive tax planning), which was considered onerous by corporations who use BEPS tools. Impact of BEPS Implementation - there was a fairly broad consensus that 1) the Action 1 VAT recommendations are being widely implemented and that they are having a significant impact on tax collection in market jurisdictions; 2) the BEPS changes are impacting business models (particularly Action 7 encouraging a shift towards buy/sell), and that consistency in business model globally was One of those particular actions is BEPS Action 7, which is titled: “Preventing the artificial avoidance of PE status”. The OECD did extensive research on this subject, to which extent they consulted the public twice3, which resulted in a final report on Action 7 in October 2015.4 Previous to the BEPS-project, the OECD BEPS Action 8, 9 and 10 Assure that transfer pricing outcomes are in line with value creation Action 8: Intangibles Page 6 New TP approach for intangibles .

Approach to improving treaty-related disputes under MAP The Discussion Draft sets out the intention to introduce a ‘three-pronged approach’ to improving MAP resolution of disputes. introduction of the principal purposes test under BEPS Action 6 on preventing treaty abuse.

We do understand and support the idea that Report of the work of the OECD/G20 on the BEPS action 6 ―Preventing the granting of Treaty Benefits in Inappropriate Circumstances‖ where OECD proposed the three-pronged approach on preventing treaty abuse. 5 The first recommendation regards the inclusion in the tax treaties of a BEPS Action 6 INTRODUCTION 1. At the request of the G20, the OECD published its Action Plan on Base Erosion and Profit Shifting (Action Plan)1 in July 2013. The BEPS Action Plan includes 15 actions to address BEPS in a comprehensive manner and sets deadlines to implement these actions. 2. The Discussion Draft recommends a three-pronged approach to address situations of treaty shopping: a) Clarify in the title and the preamble of tax treaties that tax treaties are not intended to generate double non-taxation and that the Contracting States intend to prevent tax evasion and avoidance. b) Include in tax treaties a LOB provision based on The Action Plan on Base Erosion and Profit Shifting (“BEPS Action Plan”) identified 15 actions to address BEPS in a comprehensive manner.

Action 6 – Treaty abuse • Treaty abuse is one of the most important sources of BEPS concerns • Three pronged approach to deal with Treaty shopping − A statement that Treaties intend to avoid tax evasion / avoidance / Treaty shopping (minimum standard); and − Inclusion of LOB rule in Treaties; and / or Action 14: Three-pronged approach Three-pronged approach would consist: • Political commitments to effectively eliminate taxation not in accordance with the OECD Model Tax Convention on Income and on Capital • Provide new measures to improve access to the MAP and improved procedures out in the September 2014 the OECD Report9 on Action 6 was however criticised for its complexity. Even in the US, application of the LOB has given rise to considerable difficulties in practice and is continuously being 7 OECD/G20 2015 Final Report on Action 6 at 21. 8 Published in Government Gazette No. 185553 of 15/12/1997.
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Action 7: The OECD recommended a three-tiered approach to. The basic framework of Action 6 is based on a three- pronged approach to be used by countries to release new treaties or to modify existing ones: 1. a clear  Although recommending this three-pronged approach to tax treaty shopping, the final report on BEPS action 6 acknowledges that states might have legitimate.

introduction of the principal purposes test under BEPS Action 6 on preventing treaty abuse. The Discussion Draft proposes that countries commit to providing access to MAP even in cases involving anti-abuse rules. Alternatively, it suggests that countries notify treaty partners of circumstances where access to MAP is denied.
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Action 6 – Preventing the granting of treaty benefits in inappropriate circumstances Introduction On 5 October 2015, the Organisation for Economic Co - operation and Development (OECD) released final reports in connection with all its 15 Action Plans on Base Erosion and Profit Shifting (BEPS). The BEPS Action 6

See EY Global Tax Alert, OECD releases peer review documents on BEPS Action 5 on Harmful Tax Practices and on BEPS Action 13 on Country-by-Country Reporting, dated 6 February 2017. See EY Global Tax Alert, OECD releases first annual peer review report on Action 5, dated 5 December 2017. 5.1 Approach number of BEPS Actions to each other, and since the BEPS-project is a huge and ambitious project of the OECD, this research may show how closely connected this huge project actually is. The methodology used to perform the research consists of various steps. On 1 February 2017, the OECD released the first peer review documents on BEPS Action 13. 1 According to the methodology included in the peer review documents, the peer review follows a staged approach. The peer reviews consist of three phases structured into annual reviews, starting respectively in … 2.