Prevention of Tax Treaty Abuse – Third Peer Review Report on Treaty Shopping
Inclusive Framework on BEPS: Action 6
The BEPS Action 6 minimum standard on preventing the granting of treaty benefits in
inappropriate circumstances, is one of the four BEPS minimum standards that all members
of the OECD/G20 Inclusive Framework on BEPS (Inclusive Framework) have committed to
implement. This report reflects the outcome of the third peer review of the implementation
of the Action 6 minimum standard on treaty shopping as approved by the Inclusive Framework.
It includes the aggregate results of the review and data on tax treaties concluded
by each of the 137 members of the Inclusive Framework on 30 June 2020 and it contains
the jurisdictional section for each member. The data compiled for this peer review
demonstrate that the MLI has been the tool used by the vast majority of jurisdictions
that have begun to implement the minimum standard and that the MLI has started to
impact tax treaties of jurisdictions that have ratified it.
Published on April 01, 2021Also available in: French