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BEPS Action 6 and private equity funds

Matthew D Saronson and Ceinwen Rees (Debevoise & Plimpton) examine the application of new anti-treaty abuse provisions to private equity fund structures.
 

Readers or watchers of Agatha Christie’s Murder on the Orient Express will know that anything involving 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.

Action 6 refresher

Action 6 as set out by Michael McGowan and Andrew Thomson (‘BEPS: preventing treaty abuse’ Tax Journal 31 October 2015) is about preventing treaty abuse. This will be achieved via the inclusion in double tax treaties of:

  • a clear statement that the treaty’s aim is the prevention of tax avoidance; and

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