Tax treaties

Preventing the Granting of Treaty Benefits in Inappropriate Circumstances, Action 6 - 2015 Final Report

In series:OECD/G20 Base Erosion and Profit Shifting Projectview more titles

Published on October 05, 2015

Also available in: German, Spanish, French

This report includes changes to the OECD Model Tax Convention to prevent treaty abuse. It first addresses treaty shopping through alternative provisions that form part of a minimum standard that all countries participating in the BEPS Project have agreed to implement.  It also includes specific treaty rules to address other forms of treaty abuse and ensures that tax treaties do not inadvertently prevent the application of domestic anti-abuse rules. The report finally includes changes to the OECD Model Tax Convention that clarify that tax treaties are not intended to create opportunities for non-taxation or reduced taxation through tax evasion or avoidance (including through treaty-shopping) and that identify the tax policy considerations that countries should consider before deciding to enter into a tax treaty with another country.







Base Erosion and Profit Shifting (BEPS) refers to tax planning strategies that exploit gaps and mismatches in tax rules to artificially shift profits to low or no-tax locations where there is little or no economic activity, resulting in little or no overall corporate tax being paid.



Watch an example of how the OECD/G20 BEPS Project will revise the international tax rules.