to BEPS Action 6 be addressed with a LOB, or a PPT included in tax treaties. There are several issues regarding the suggested measures, the broad formulation creating legal uncertainty regarding the PPT and the complexity of the LOB. The least extensive suggestion

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.

It also includes specific treaty rules to address other forms of treaty abuse and ensures that tax treaties do not 2015-10-05 BEPS Action 6 identifies treaty shopping as one of the most important sources of BEPS concerns. Countries that do not have anti-abuse provisions in their tax treaties are exposed to lower tax revenues. Therefore it has been agreed between countries to include anti-abuse provisions in their tax treaties, including a minimum standard to counter Action 6 of the BEPS Action Plan identified treaty abuse, and in particular treaty shopping, as one of the most important sources of BEPS concerns. One of it Action 6 Action 6 of the BEPS initiative has the following three pur - poses: (1) preventing the granting of treaty benefits in inappro - priate circumstances; (2) clarifying that tax treaties are not intended to be used to generate double non-taxation; and International/OECD - Action 6 of the OECD/G20 BEPS Initiative: The Effect on Holding Companies.

Action 6 beps

Action 6 targets, in summary, "treaty shopping", i.e., where a person in country A, which is not, in principle, eligible to benefit from a given tax treaty with country B, invests through an entity in country C to benefit from the treaty. In BEPS Action 6 an approach is recommended to address treaty shopping situations-First, a clear statement that the Contracting States, when entering into a treaty, wish to prevent tax avoidance and, in particular, intend to avoid creating opportunities for treaty shopping will be included in tax treaties. BEPS Action 6 - An inclusion of anti-abuse measures in tax treaties to prevent the improper use of a tax treaty - Are the measures suggested in BEPS Action 6 necessary from a Swedish perspective? Fridh, Johanna LU HARN60 20161 Department of Business Law. Mark; Abstract First Action 6 peer review report.

LOB. Paragraph 1 – 6 of a new “Article 10 (Entitlement to Benefits)” contains the model treaty provisions of the LOB rule. The LOB rule, as proposed in the final report, limits the availability of treaty benefits to persons that are “qualified persons”.

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

It also includes specific rules and recommendations to address other forms of treaty abuse. 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)).

Base Erosion and Profit Shifting (BEPS) Action Plan The BEPS Inclusive Framework (IF) comprises around 130 countries BEPS Action Plan: Action 6 -.

Taxpayers engaged in treaty shopping and other treaty abuse strategies undermine tax 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. 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 BEPS Action 6 - An inclusion of anti-abuse measures in tax treaties to prevent the improper use of a tax treaty Are the measures suggested in BEPS Action 6 necessary from a Swedish perspective?

(6) Se EESK:s yttranden om ”Bekämpning av skattebedrägerier och skatteflykt” (EUT C 198, 10.7.2013, s. 34) och Företagen som kontaktades är listade på Nasdaq OMX Nordic Stockholm. Rapporten är en del i ActionAid's globala arbete kring aggressiv skatteplanering. 6 Veroasiat kehitysyhteistyössä . KOM(2012) 722 lopullinen. 2 Action Plan on Base Erosion and Profit Shifting, OECD 2013.
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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. 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.

Each of the four BEPS minimum Se hela listan på skatteverket.se 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 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.
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The BEPS Action 6 minimum standard on preventing the granting of treaty benefits in inappropriate circumstances, is one of the four BEPS minimum standards that all members of the OECD/G20 Inclusive Framework on BEPS (Inclusive Framework) have committed to implement.

A final report on Action 6 was released by the OECD as part of its 5 October 2015 package of final reports.