Tax treaties

CTP Third Roundtable on Collective Investment Vehicles


The OECD Centre for Tax Policy and Administration (the CTPA) organised its annual policy roundtable for in Paris on 1-2 February 2006.  The theme was “Selected Tax Issues related to Collective Investment Vehicles”. 

The CTPA roundtables are intended as a response to the broadly expressed desire to have the OECD more involved in the consideration of current tax policy issues and to engage in a wider dialogue with private sector participants on such issues.
Business participants, independent advisors and academics are invited to CTPA roundtables to give an overview of the issues involved from their perspectives and to set out the current state of research on these questions. Senior officials from OECD Member countries are also invited to describe their experience with particular policy choices. This approach encourages an informal exchange of views.

Below is the list of presentations and documents submitted by the participants for the three topics that were discussed during the meeting.



Topic A: 

Treaty relief from withholding taxes: the problems arising from the use of collective investment vehicles, and possible coordinated approaches to ensuring that  tax treaty relief is appropriately granted to investments by collective investment vehicles


Stephen Shay, Ropes & Gray LLP, Boston, United States
"Selected treaty issues affecting collective investment funds investing in securities"

Chris Gilbert, JP Morgan Chase Bank, United Kingdom
"A Group of 30 (G30) proposal for a standardised system of obtaining withholding tax relief on investment income flowing through intermediaries"
G30 proposal

General note from the Securities Industry Association relevant to this topic

Topic B:

Issues to be taken into account in designing an immovable property regime for collective investment vehicles


Tony Edwards, National Association of Real Estate Investment Trusts, United States
"REITs - the United States experience"

Michael Fekete, HM Treasury, United Kingdom
"Recent developments in the United Kingdom concerning immovable property regimes"
December 2005 UK announcement on REIT legislation 
Note from the Property Council of Australia relevant to this topic

Topic C: 

Issues arising from the use of income trusts and similar vehicles


 Brian Ernewein, Department of Finance, Canada
"The Canadian experience with income trusts"


Related Documents