BEPS – Uppdaterat utkast avseende missbruk av skatteavtal

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The BVCA is the industry body and public policy advocate for the private equity and venture capital industry in the UK. With a membership of almost 600 firms, the BVCA represents the vast majority of Action to fight corporate tax avoidance has been deemed necessary in the OECD forum has and received further impetus through the G20/OECD Base e rosion and p rofit shifting action plan (known as BEPS). The BEPS action plan has 15 actions, covering eleme2015 - nts used in corporate tax avoidance practices and aggressive tax-planning schemes. The OECD recently published its peer review report on treaty shopping re: prevention of treaty abuse under the inclusive framework on BEPS Action 6. A link to the document is included for reference. Article 6 targeted treaty abuse; Action 15 introduced the multilateral instrument (MLI) to implement BEPS actions. Koriak, Oleksandr: The Principal Purpose Test under BEPS Action 6: Is the OECD Proposal Compliant with EU Law? European Taxation, Volume 56, 12/2016, s. 552–559.

Ppt beps action 6

1. for the purpose of combating abuse of tax treaties. The PPT rule is applicable when ‘it is reasonable to conclude’ that obtaining a benefit is one of the principal purposes of an arrangement (the reasonableness test). In accordance with BEPS action 6, countries have committed to adopting a minimum standard into tax treaties to combat treaty shopping. The minimum standard contains an LOB provision and/or a PPT rule. Action 6 (Treaty Abuse) is a key element of the OECD's BEPS Project.

discipline:"Accounting and Law" – OATD

1, paras. 10 and 11 of the Commentary on the PPT rule. analysis of the aims and objects of all persons involved in putting that arrangement or transaction in place or being a party to it.

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I am writing on behalf of BVCA to comment on the examples in the public discussion draft. The BVCA is the industry body and public policy advocate for the private equity and venture capital industry in the UK. With a membership of almost 600 firms, the BVCA represents the vast majority of Action to fight corporate tax avoidance has been deemed necessary in the OECD forum has and received further impetus through the G20/OECD Base e rosion and p rofit shifting action plan (known as BEPS). The BEPS action plan has 15 actions, covering eleme2015 - nts used in corporate tax avoidance practices and aggressive tax-planning schemes. The OECD recently published its peer review report on treaty shopping re: prevention of treaty abuse under the inclusive framework on BEPS Action 6.

BEPS Action 6 addresses treaty shopping through treaty provisions whose adoption forms part of a minimum standard that members of the BEPS Inclusive Framework have agreed to implement. It also includes specific rules and recommendations to address other forms of treaty abuse. Action 6 of the OECD/G20 BEPS Project identifies treaty abuse (with a particular focus on treaty shopping) as a BEPS concern. This Action has produced multiple alternatives to afford Contracting States flexibility but at the same time ensuring that the common goal of implementing safeguards within the treaty against treaty abuse is achieved.
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2019-07-04 Action 6 Prevention of tax treaty abuse Minimum Standard. BEPS Action 6 addresses treaty shopping through treaty provisions whose adoption forms part of a minimum standard that members of the BEPS Inclusive Framework have agreed to implement. It also includes specific rules and recommendations to address other forms of treaty abuse.

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. 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.
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En analys av OECDs föreslagna åtgärder i Action 6, särskilt

The author can be contacted at bkuzniacki@smu.edu.sg or/and blazej.kuzniacki@gmail.com. Note: The article will be published by IBFD at World Tax Journal 2018, Issue 2. The Principal Purposes Test (PPT) in BEPS Action 6/MLI: In our previous post published on 6 December 2016 we described the OECD’s BEPS Project in the context of the publishing of the draft Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (the “Convention”)..