The BEPS limitation on benefits article would hinder cross-border investment. Dan Neidle and Jemma Dick (Clifford Chance) consider why it’s likely to be of limited application.
On 7 June 2017 68 countries signed the BEPS multilateral convention (‘the Convention’) the effect of which is to modify more than 1 100 existing double tax treaties between the signatory countries. This follows the work undertaken over the last four years by the OECD on BEPS Action 6 the purpose of which is to counter treaty abuse.
After years of uncertainty we finally know which countries are opting for what variant of the proposed anti-abuse rules and therefore the investments that are most likely to be adversely affected.
What is BEPS Action 6?
The BEPS project was launched by the OECD and G20 in 2013 to tackle ‘base erosion and profit shifting’; i.e. tax planning strategies...
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The BEPS limitation on benefits article would hinder cross-border investment. Dan Neidle and Jemma Dick (Clifford Chance) consider why it’s likely to be of limited application.
On 7 June 2017 68 countries signed the BEPS multilateral convention (‘the Convention’) the effect of which is to modify more than 1 100 existing double tax treaties between the signatory countries. This follows the work undertaken over the last four years by the OECD on BEPS Action 6 the purpose of which is to counter treaty abuse.
After years of uncertainty we finally know which countries are opting for what variant of the proposed anti-abuse rules and therefore the investments that are most likely to be adversely affected.
What is BEPS Action 6?
The BEPS project was launched by the OECD and G20 in 2013 to tackle ‘base erosion and profit shifting’; i.e. tax planning strategies...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
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