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Search results with tag "Granting of treaty benefits"
BEPS ACTION 6: PREVENTING THE GRANTING OF TREATY …
www.oecd.orgDevelop model treaty provisions and recommendations regarding the design of domestic rules to prevent the granting of treaty benefits in inappropriate circumstances.
2017 UPDATE TO THE MODEL TAX CONVENTION - OECD
www.oecd.orgPreventing the Granting of Treaty Benefits in Inappropriate Circumstances). • The addition of new paragraph 2 to Article 1 (the transparent entity provision) and of related Commentary changes. These changes appear in Chapter 14 of the Report on Action 2 (Neutralising
The principal purpose test in tax treaties under BEPS 6 - EY
www.ey.comThe Principal Purpose Test in Tax Treaties under BEPS 6 Reinout Kok* In report 6 of the BEPS action plan, Preventing the Granting of Treaty Benefits in Inappropriate Circumstances, the Organisation for Economic