Conventions fiscales

Release of a revised discussion draft on BEPS Action 6 (Prevent Treaty Abuse)


22/05/2015 – Public comments are invited on a revised discussion draft which includes proposals on how to deal with the follow-up work on Action 6 (Prevent Treaty Abuse)  of the Action Plan on Base Erosion and Profit Shifting (BEPS).


On 21 November 2014, the OECD released a discussion draft that identified 20 different issues to be addressed as part of the follow-up work mandated by the September 2014 Report on Action 6. At its March 2015 meetings, Working Party 1 on Tax Conventions and Related Questions continued its work on these issues in the light of the comments received, agreed on how to address the majority of these issues and discussed new proposals related to some issues.


This new discussion draft reflects the conclusions and proposals that resulted from that meeting and on which the Committee on Fiscal affairs is now inviting comments. The discussion draft and the comments received on it will be discussed at the Working Party 1 meeting of 22-26 June 2015, when the Working Party will be asked to produce a final version of the Report on Action 6 that will take into account the conclusions of the follow-up work done on the issues identified in the November 2014 discussion draft.


Comments should be sent by 17 June 2015 at the latest (no extension will be granted) and should be sent by email to in Word format (in order to facilitate their distribution to government officials). They should be addressed to Marlies de Ruiter, Head, Tax Treaties, Transfer Pricing and Financial Transactions Division, OECD/CTPA.


Comments should be kept as short as possible: this is the third discussion draft related to Action 6 and extensive comments have already been sent on the different proposals resulting from the work on that part of the BEPS Action Plan. For the same reason, no public consultation meeting will be held on the proposals included in this new discussion draft.


Please note that all comments received regarding this consultation draft will be made publicly available. Comments submitted in the name of a collective “grouping” or “coalition”, or by any person submitting comments on behalf of another person or group of persons, should identify all enterprises or individuals who are members of that collective group, or the person(s) on whose behalf the commentator(s) are acting.