OECD consults on tax treaty benefits for non-CIV funds under BEPS rules

The OECD has requested taxpayer input on how to apply rules on entitlement to tax treaty benefits to non-CIV funds, which are investment vehicles that do not qualify as collective investment vehicles.

The March 24 OECD consultation document addresses the impact of provisions in the final report on action 6 of the OECD/G20 base erosion profit shifting (BEPS) plan on non-CIV funds and possible methods to address these concerns. Specifically, the consultation focuses on the impact on non-CIV funds of new BEPS rules on limitation on benefits, the principal purpose test, the anti-conduit rules, and special tax regimes.

Comments are requested by April 22 on a series of questions and proposals.

See:

• Consultation