Allan Cinnamon reviews the latest tax treaty developments this month, including BEPS Action 6; amendments to the US Model Tax Treaty; diverted profits in Australia; PE profit allocations; a Swiss Supreme court decision on beneficial ownership of dividends; and treaty provisions relating to PEs, equipment leasing and hybrids.
On 22 May the OECD
released a revised discussion draft on Action 6 (preventing treaty abuse). This is part of the follow-up work indicated in its previous 21 November 2014 draft. It suggests and sets out a simplified limitation on benefits (LOB) rule to be included in the OECD Model (including application to CIV and non-CIV funds) and discusses issues...
