Preventing the Granting of Treaty Benefits in Inappropriate Circumstances
This report includes proposed changes to the OECD Model Tax Convention to prevent
treaty abuse. Countries participating in the BEPS Project have agreed on a minimum
standard to prevent treaty shopping and other strategies aimed at obtaining inappropriately
the benefit of certain provisions of tax treaties. The report also ensures that tax
treaties do not inadvertently prevent the application of legitimate domestic anti-abuse
rules. The report clarifies that tax treaties are not intended to be used to generate
double non-taxation and identifies the tax policy considerations that countries should
consider before deciding to enter into a tax treaty with another country. The model
provisions included in the report provide intermediary guidance as additional work
is needed, in particular in relation to the limitation on benefits rule.
Published on September 16, 2014Also available in: French, Korean, Chinese
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