The OECD has published its second discussion draft relating to BEPS Action 7 (the artificial avoidance of permanent establishment status); and, at the time of writing, publication of the revised discussion draft on Action 6 (preventing treaty abuse) was imminent. In Europe this month, the CJEU has ruled that Germany’s roll-over relief rules are contrary to EU law, which may impact the UK’s roll-over relief rules. Greece has issued guidance in respect of the rules which introduce a ‘withholding tax’ on the payment of certain expenses. Further afield, Australia and Canada show very different approaches to implementing BEPS; and New Zealand considers changes to its withholding tax regime.
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