The Discussion Draft recommends a three-pronged approach to address situations of treaty shopping: a) Clarify in the title and the preamble of tax treaties that tax treaties are not intended to generate double non-taxation and that the Contracting States intend to prevent tax evasion and avoidance. b) Include in tax treaties a LOB provision based on

BEPS Action 14: Make Dispute Resolution Mechanisms More Effective The Organization for Economic Cooperation and Development on December 18, 2014, must be read in the broader context of the intention to introduce a three-pronged approach designed to represent a step change in the resolution of treaty-related disputes through the MAP.

There are 15 BEPS Actions that are currently being considered and worked on by the OECD. For each of the Actions, there are factors to consider such as the timing, impact and potential impact on policy. The OECD has set a number of deadlines to conclude on the BEPS Actions. Action 6 - Treaty Benefits Action 6 identifies treaty abuse, and in particular treaty shopping as one of the most important sources of BEPS concerns. The report suggests that the following three pronged approach be taken to tackle treaty abuse: 1) First, a clear statement in tax treaties that the Contracting States, when entering into a treaty, 2014-03-01 One of the key actions in preventing BEPS is Action 6, Preventing Treaty Abuse which includes combatting treaty shopping.

Beps action 6 three-pronged approach

The Action Plan identifies treaty abuse, and in particular treaty shopping, as one of the most important sources of BEPS concerns. Action 6 The OECD proposal provides a three-pronged approach: Treaty statement re: anti-avoidance rule and treaty shopping opportunities; Specific anti-abuse rule based on Limitation of Benefit Action 6 of the OECD/G20 BEPS Project[6] 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. 2014-12-26 United Kingdom: BEPS Actions implementation Last updated: May 2017 More information on the Global Tax Reset & BEPS >>> Back to BEPS Actions >>> Interest deductions (Action 4) Common approach Following public consultation, draft legislation restricting corporate interest tax deductibility was issued in … group action is more complex and takes time to work out. Such is the case with the OECD’s approach to non-collective investment vehicle funds (non-CIV funds) and their interaction with the BEPS Action 6 on preventing the granting of treaty benefits in inappropriate circumstances.

6. ActionPlan1–DigitalEconomy Action 1: Addressing the tax challenges of the Digital Economy (‘DE’) • No special tax regime has been prescribed. BEPS measures under other Action Plans seek to address these challenges.

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2. See EY Global Tax Alert, OECD releases peer review documents on BEPS Action 5 on Harmful Tax Practices and on BEPS Action 13 on Country-by-Country Reporting, dated 6 February 2017. 3.

Action 14: Three-pronged approach Three-pronged approach would consist: • Political commitments to effectively eliminate taxation not in accordance with the OECD Model Tax Convention on Income and on Capital • Provide new measures to improve access to the MAP and improved procedures

Although recommending this “three-pronged approach” to tax treaty shopping, the Final Report of BEPS Action 6 initially introduced, was to implement the expected outcome of BEPS Action 6. reporting system based on the three-tiered approach introduced in the 2016 tax 14 Mar 2014 Action 6 (Prevent Treaty Abuse) describes the work to be undertaken that the following three-pronged approach be used to address treaty 14 Jul 2014 In July 2013 the OECD released its “BEPS Action Plan”, which 15 actions points, one of which is “Action 6 – Prevent Treaty Abuse”. In particular, the discussion draft recommended the following “three-pronged approa 23 Jul 1992 Action 6 report, is that Finance will propose draft domestic anti-treaty- also conflict with the OECD public discussion draft on BEPs Action 6.9 within case 1 .72 The Action 6 report recommends a three-pronged appro 16 Sep 2014 The remaining eight BEPS Action Plan deliverables are due in 2015. Action 6 in the BEPS Action Plan had identified treaty abuse, and in The new Chapter V provides for a three-tiered approach to transfer pricing&nbs This legal update discusses the BEPS proposals and identifies action items and of Treaty Benefits in Inappropriate Circumstances – Action 6 (the Action 6 Final The Revised Guidelines also adopt a three-tiered standardized approach 15 Feb 2019 OECD releases first annual peer review report on BEPS Action 6 tax evasion or avoidance, and one of three methods of addressing treaty shopping. standards to reinforced international standards, common approaches to 5 Oct 2015 Although the reports have been billed as the 'final' BEPS reports and shopping (Action Point 6), Country-by-Country Reporting (Action 13), 26 Nov 2015 Session 6 of 8 part OECD BEPS seriesSign up for upcoming live project outcomes Part 6: Anti-abuse Measures under Actions 3, 5, 6 and 12.

They will also be able to monitor the evolution of the tax raised by the digital economy challenges (Action 1) and Action 10 . Assuring that TP outcomes are in line with value creation (Other high-risk transactions) Action 11 .
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2. The Discussion Draft recommends a three-pronged approach to address situations of treaty shopping: a) Clarify in the title and the preamble of tax treaties that tax treaties are not intended to generate double non-taxation and that the Contracting States intend to prevent tax evasion and avoidance. b) Include in tax treaties a LOB provision based on The Action Plan on Base Erosion and Profit Shifting (“BEPS Action Plan”) identified 15 actions to address BEPS in a comprehensive manner.

BEPS measures under other Action Plans seek to address these challenges. • Destination based tax for GST / VAT Indian perspective Impact of BEPS Implementation - there was a fairly broad consensus that 1) the Action 1 VAT recommendations are being widely implemented and that they are having a significant impact on tax collection in market jurisdictions; 2) the BEPS changes are impacting business models (particularly Action 7 encouraging a shift towards buy/sell), and that consistency in business model globally was The MLI also implements the BEPS Action 6 minimum standard by implementing a principal purpose test (PPT). Under the PPT rule, a tax treaty benefit is denied where one of the principal purposes of an arrangement or transaction is to directly or indirectly obtain the benefit, unless the granting of that benefit in the circumstances would be in accordance with the object and purpose of the See EY Global Tax Alert, OECD releases final reports on BEPS Action Plan, dated 6 October 2015. See EY Global Tax Alert, OECD releases peer review documents on BEPS Action 5 on Harmful Tax Practices and on BEPS Action 13 on Country-by-Country Reporting, dated 6 February 2017.
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The BEPS Action Plan states that “Treaty abuse is one of the most important sources of BEPS concerns”, and then describes Action 6 as recommended the following “three-pronged approach”:

The peer reviews consist of three phases structured into annual reviews, starting respectively in … 2. See EY Global Tax Alert, OECD releases peer review documents on BEPS Action 5 on Harmful Tax Practices and on BEPS Action 13 on Country-by-Country Reporting, dated 6 February 2017. 3. See EY Global Tax Alert, OECD releases progress report on preferential regimes under BEPS Action 5, … 2021-03-24 See EY Global Tax Alert, OECD releases peer review documents on BEPS Action 5 on Harmful Tax Practices and on BEPS Action 13 on Country-by-Country Reporting, dated 6 February 2017. See EY Global Tax Alert, OECD releases first annual peer review report (Phase 1) on Action 13, dated 29 May 2018. See EY Global Tax alert, OECD releases outcomes of the second phase of peer reviews on BEPS Action 13 1.

The BEPS report, previously released, and the new Action Plan are available for public review, with many commentators already providing insight on the Action Plan. The 24 month Action Plan is comprehensive and aggressive, with tax transparency and disclosure rules likely to be implemented early in that timeline.

2. The Action Plan identifies treaty abuse, and in particular treaty shopping, as one of the most important sources of BEPS concerns.

See EY Global Tax Alert, OECD releases final report on countering harmful tax practices under Action 5, dated 8 October 2015. 2. See EY Global Tax Alert, OECD releases peer review documents on BEPS Action 5 on Harmful Tax Practices and on BEPS Action 13 on Country-by-Country Reporting, dated 6 February 2017. 3.