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  • 5-October-2015

    English

    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.  It also includes specific treaty rules to address other forms of treaty abuse and ensures that tax treaties do not inadvertently prevent the application of domestic anti-abuse rules. The report finally includes changes to the OECD Model Tax Convention that clarify that tax treaties are not intended to create opportunities for non-taxation or reduced taxation through tax evasion or avoidance (including through treaty-shopping) and that identify the tax policy considerations that countries should consider before deciding to enter into a tax treaty with another country.
  • 15-June-2015

    English

    Public comments received on revised discussion draft on Action 7 (Prevent the Artificial Avoidance of PE Status) of the BEPS Action Plan

    On 15 May 2015, interested parties were invited to comment on a revised discussion draft on Action 7 (Prevent the Artificial Avoidance of PE Status) of the BEPS Action Plan.

  • 15-May-2015

    English

    Release of a new discussion draft on BEPS Action 7 (Prevent the Artificial Avoidance of PE Status)

    Public comments are invited on a new discussion draft which includes proposals resulting from the work on Action 7 (Prevent the Artificial Avoidance of PE Status) of the Action Plan on Base Erosion and Profit Shifting (BEPS).

  • 31-October-2014

    English

    Release of discussion draft on Action 7 (Prevent the Artificial Avoidance of PE Status) of the BEPS Action Plan

    The Committee on Fiscal Affairs (CFA) invites interested parties to send comments on this discussion draft, which includes the preliminary results of the work carried on with respect to issues related to the artificial avoidance of PE status and includes proposals for changes to the definition of permanent establishment found in the OECD Model Tax Convention.

  • 16-September-2014

    English

    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.
  • 14-March-2014

    English

    Release of discussion draft on Action 6 (Prevent Treaty Abuse) of the BEPS Action Plan

    Public comments are invited on a discussion draft that includes the proposals produced with respect to Action 6 (Prevent Treaty Abuse) of the BEPS Action Plan.

  • 16-January-2014

    English

    OECD publishes comments received on strategies that allegedly result in the artificial avoidance of PE Status

    On 22 October 2013, the OECD requested interested parties to send a short description of strategies that might be considered to result in the artificial avoidance of PE status in relation to base erosion and profit shifting. The OECD has now published the only response received following that invitation.

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  • 16-August-2010

    English

    Public comments received on the discussion draft on the application of Article 17 (Artistes and Sportsmen) of the OECD Model Tax Convention

    The OECD has published the comments received on a proposed draft of the new Article 17 of the OECD Model Tax Convention (Artistes and Sportsmen).

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  • 20-November-2009

    English

    African Tax Administration Forum launched on 19-20 November 2009

    On 19-20 November the African Tax Administration Forum (ATAF) was launched by the President of Uganda.

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  • 21-September-2009

    English

    OECD holds a major Conference “Transfer Pricing and Treaties in a Changing World”

    On 21-22 September 2009, the OECD held a major conference “Transfer Pricing and Treaties in a Changing World”.

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