OECD BEPS project final reports Introduction The BEPS (base erosion and profit shifting) is a joint project between the OECD and the G20 which takes action against erosion of the tax base and profit shifting in jurisdictions with low or no taxation. In particular, the interactions between national tax

Each working group prepared a final report following earlier draft versions since the start of the project over two years ago. As the tax and financial world dive deeper into the many technical aspects of the reports (in excess of 1,000 pages) we have set out below some key notes that put the final BEPS reports …

Action 6 targets, in summary, "treaty shopping", i.e., where a person in country A, which is not, in principle, eligible to benefit from a given tax treaty with country B, invests through an … 1 OECD/G20 2015 Final Report on Action 11 at 15. 2 OECD/G20 2015 Final Report on Action 11 at 80. 3 See 2013 OECD/G20 BEPS report on action 11 at 58-60. 4 Ibid. 5 OECD/G20 2015 Final Report … This report is the final report for the peer review process on BEPS Action 5, as agreed in the current review methodology. The Inclusive Framework is now working to ensure that the progress made on ensuring transparency with respect to tax rulings is maintained in the future, both through a review of the overall effectiveness of Action 5 and the development of a peer review process for the 2019-10-09 1. See EY Global Tax Alert, OECD releases final reports on BEPS Action Plan, dated 6 October 2015.

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This report reflects the outcome of the first peer review of the implementation of the Action 6 minimum standard on treaty shopping as approved by the Inclusive Framework on BEPS 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 The Report also notes that the MLI is by far the preferred tool of the Inclusive Framework members for implementing the BEPS Action 6 minimum standard. By the cut-off date, 91 jurisdictions had some double tax agreements that either were already compliant with the minimum standard or were subject to a complying instrument (i.e., the MLI or a protocol/treaty).

It also includes specific treaty rules to address other forms of treaty abuse and ensures that tax treaties do not OECD BEPS project final reports Introduction The BEPS (base erosion and profit shifting) is a joint project between the OECD and the G20 which takes action against erosion of the tax base and profit shifting in jurisdictions with low or no taxation.

The OECD BEPS Action 6 report contains a principal pur- pose test rule Abusive Behaviour', ET, April 2015, at 155 and E. Pinetz, 'Final Report of Action 6 of 

40. 45 Revised discussion draft on BEPS Action 7, 15 maj till  med beaktande av OECD:s BEPS-handlingsplan från oktober 2015, särskilt åtgärd 1, TAX2‑utskottets resolution av den 6 juli 2016 om skattebeslut och oktober 2016) och Aggressive tax planning indicators – Final Report  Projektet benämns “Base Erosion and Profit Shifting Action Plan”, BEPS.2 Inom and Profit Shifting Project, Explanatory Statement, Final Report 2015, s.

The Action 6 Report sets out other specific rules and recommendations to address other forms of treaty abuse. To foster the implementation of the minimum standard and other BEPS treaty-related measures in the global treaty network, a Multilateral Instrument (the MLI) that can modify existing bilateral tax agreements was concluded.

July 2013. Release of 15 Action Plans to Address BEPS. 2016 Onwards. Implementation, Monitoring and further work. July – August 2014.

Because of the short time given for NSD invited to leave comments. Since the public consultation a final report has not yet. av AÖ Tjernström — det så kallade BEPS-projektet och EU-direktivet mot skatteflykt.6 Förslaget 49 OECD (2015), Final Report on action 11: Measuring and Monitoring BEPS.
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12 Preventing the granting of treaty benefits in inappropriate circumstances, Action 6: final report, OECD/G20 Base Erosion and Profit Shifting project, 5 October 2015, Commentary on the PPT rule: point 14, example C (manufacturing plant in developing country). The final OECD report will be presented to G20 Leaders in November 2015. The BEPS project will then move into the implementation phase which will be key to the project’s overall impact in the global market. The latest reports did not contain a timescale for implementation, on which the relevant parties have yet to reach agreement.

4 – 2015 Final Report, OECD, 5 oktober 2015. https://www.oecd.org/ctp/limiting-base- 6.
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See EY Global Tax Alert, OECD releases final reports on BEPS Action Plan, dated 6 October 2015. 2. See EY Global Tax Alert, OECD releases BEPS Action 14 on More Effective Dispute Resolution Mechanisms, Peer Review, dated 31 October 2016. 3.