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OECD invites comments on BEPS action 6

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The OECD invites comments by 9 January 2015 on a discussion draft dealing with follow-up work mandated by the report on action 6 of the BEPS project (preventing treaty abuse) published in September 2014. Paragraph 5 of the report, Prevent the granting of treaty benefits in inappropriate circumstances, indicated that follow-up work would be done on certain aspects of the report.

The discussion draft deals with the follow-up work related to the contents of the model provisions and related commentary included in section A of the report, in particular the LOB rule, as well as with issues related to the treaty entitlement of collective investment vehicles (CIVs) and non-CIV funds (the result of the discussions on how countries intend to implement the minimum standard described in the report will be included in the revised version of the report that will be released in 2015).