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BEPS Action 6 and treaty entitlement of non-CIV funds

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The OECD is inviting comments by 3 February 2017 on three draft examples illustrating the interaction between the treaty provisions of the report on BEPS action 6 and the treaty entitlement of funds which are not collective investment vehicles. These examples will be included in the commentary on the principal purposes test rule.

The BEPS report on action 6 (preventing the granting of treaty benefits in inappropriate circumstances) indicated that the OECD would continue to examine issues related to the treaty entitlement of non-CIV funds, to ensure that the new treaty provisions in the report address these funds. In March 2016, the OECD published a consultation document on the treaty entitlement of non-CIV funds, which included a number of specific questions. The discussion draft containing the examples has been prepared to provide stakeholders with information on the subsequent developments in this work.

See ‘BEPS action 6 discussion draft on non-CIV examples’ at

Issue: 1337
Categories: News