2 Innehåll SUMMARY 1 SAMMANFATTNING 3 FÖRORD 5 FÖRKORTNINGAR 6 1 INLEDNING Introduktion BEPS-projektet BEPS Action Plan BEPS Action 

Africa & Middle East: BEPS Action 13 Implementation. Source: KPMG International member firms. Key: Implemented Draft bills Intentions to implement No development. Total CbCR: 9 …

Moved Permanently. The document has moved here. BEPS Actions 2 and 5 Lukas Mechtler*/ Cindy Wong Siu Ching** At present, the fight against tax evasion, currently often referred to as base ero-sion and profit shifting (BEPS), has become an important issue not only at the level of the OECD as well as the EU but also for governments around the globe. journalists to use these data as well. The following list briefly mentions some specific BEPS Actions and aggregated data sources that can be used to analyse the corresponding BEPS channels. Action 6, preventing treaty abuse (and to some extent also Action 3, preventing use of active BEPS: An Interim Evaluation The article evaluates the OECD BEPS Action Plan and recent progress in light of the key insights of the BEPS: (i) progress can be achieved solely through cooperation, and the existing competition based, unilateral action dominated paradigm is destined to fail; (ii) We welcome the opportunity to respond to the OECD’s revised discussion draft regarding BEPS action 6: prevent treaty abuse dated 22 May 2015 (the “Revised Discussion Draft”). In this context, we would like to reiterate our commitment to contribute constructively to the BEPS action plan, in the BEPS Action 6: Prevention of treaty abuse Adapting to a changing environment BEPS The OECD, with the backing of the G20, published a 15 point action plan in July 2013 setting out proposals to address base erosion and profit shifting (BEPS).

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2015-06-17 · RE: OECD REVISED DISCUSSION DRAFT ON BEPS ACTION 6 The Investment Association1 welcomes the opportunity to comment on the BEPS Action 6 revised discussion draft. Once again, we are grateful to the OECD for recognising the particular concerns of the funds industry. Our comments follow below. PwC’s comments on Action 6 PwC 3 This modification eliminates the additional criteria in the current draft that would require a publicly traded company to also establish that it has a substantial presence in its residence country based on where its shares are primarily traded or where its primary place of management control takes place. work on BEPS Action 6 – preventing treaty abuse (the “Follow Up Discussion Draft”). We are very pleased that the OECD seeks the view of the stakeholders in the investment management industry in order to find appropriate solutions for CIVs and non-CIVs in connection with the work on BEPS Action 6 – Treaty Abuse.

Please find attached INREV’s response to OECD’s “Revised Discussion Draft BEPS Action 6: Prevent Treaty Abuse”, 22 May 2015 – 17 June 2015. We hope again to provide a meaningful contribution to your work to support the development of a

2015-06-17 · RE: OECD REVISED DISCUSSION DRAFT ON BEPS ACTION 6 The Investment Association1 welcomes the opportunity to comment on the BEPS Action 6 revised discussion draft. Once again, we are grateful to the OECD for recognising the particular concerns of the funds industry. Our comments follow below. PwC’s comments on Action 6 PwC 3 This modification eliminates the additional criteria in the current draft that would require a publicly traded company to also establish that it has a substantial presence in its residence country based on where its shares are primarily traded or where its primary place of management control takes place.

Therefore, should BEPS actions were implemented, they would impose a restrictive or discriminatory tax treatment on cross-border transactions merely because they involve more than one state. In this respect, the PPT provision proposed under BEPS Action 6 is not an exception.

Once again, we are grateful to the OECD for recognising the particular concerns of the funds industry. Our comments follow below. BEPS MONITORING GROUP Revised Discussion Draft for BEPS Action 6: Prevent Treaty Abuse This response is submitted by the BEPS Monitoring Group (BMG). The BMG is a group of experts on various aspects of international tax, set up by a number of civil society organizations which research and campaign for tax justice including the Global Alliance for The OECD’s public discussion draft ‘BEPS Action 6: Preventing the Granting of Treaty Benefits in Inappropriate Circumstances’ proposed a series of rules for the OECD model. The draft for Article X, ‘‘Entitlement to Benefits,’’ the first five paragraphs of which are described therein as ‘‘specific antiabuse rule aimed at treaty Action 6 (Treaty Abuse) is a key element of the OECD's BEPS Project. Action 6 targets, in summary, "treaty shopping", i.e., where a person in country A, which is not, in principle, eligible to benefit from a given tax treaty with country B, invests through an entity in country C to benefit from the treaty.

Taxpayers engaged in treaty shopping and other treaty abuse strategies undermine tax BEPS Action 6: Preventing the granting of treaty benefits in inappropriate circumstances On 22 May 2015 the OECD, as part of its work on the Action Plan to address Base Erosion and Profit Shifting (‘BEPS’), released a Revised Discussion Draft on Action 6 in relation to preventing the granting of treaty benefits in inappropriate circumstances. In September 2015, the OECD released the final report on BEPS action 6. The main purpose of the action 6 is the prevention of ―granting treaty benefits in inappropriate circumstances‖. Regarding the prevention of treaty abuse the OECD presented three main recommendations. These actions are only proposals and therefore they constitute soft law.
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The Indian GAAR would empower the revenue authorities to go deeper into the transactions and/or arrangements (e.g. looking at ownership structures, beneficial a 15-point Action Plan to address BEPS. This report is an output of Action 6.

(DAC 6) med beaktande av grundläggande krav på tydlighet och rapport ”Mandatory Disclosure Rules ACTION 12:2015 Final Report”, som gjorts av OECD inom ramen för BEPS-projektet och saknar koppling till svenska s%C3%A4ttning-%20g%C3%A4llande%20r%C3%A4tt%20och%20empiri.pdf  BEPS-projekt, men informationen är inte offentlig utan delas mellan myndigheter. 6 Regeringens skrivelse 2015/16:182, Politiken för global utveckling i  Mercedes levererar barnvagn. mercedes barnvagn.
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n a sequel to my earlier summary on BEPS- Action 2 report, I have again attempted to summarize the Action 6 Report – Preventing the Granting of Treaty Benefits in Inappropriate Circumstances. In said report, OCED has proposed to prevent the benefits

Taxpayers engaged in treaty shopping and other treaty abuse strategies undermine tax BEPS Action 6: Preventing the granting of treaty benefits in inappropriate circumstances On 22 May 2015 the OECD, as part of its work on the Action Plan to address Base Erosion and Profit Shifting (‘BEPS’), released a Revised Discussion Draft on Action 6 in relation to preventing the granting of treaty benefits in inappropriate circumstances. In September 2015, the OECD released the final report on BEPS action 6. The main purpose of the action 6 is the prevention of ―granting treaty benefits in inappropriate circumstances‖. Regarding the prevention of treaty abuse the OECD presented three main recommendations. These actions are only proposals and therefore they constitute soft law. n a sequel to my earlier summary on BEPS- Action 2 report, I have again attempted to summarize the Action 6 Report – Preventing the Granting of Treaty Benefits in Inappropriate Circumstances.