OECD releases 40 comments to consultation on tax treaty entitlement for non-CIV funds

The OECD on April 27 released comments from 40 organizations responding to a discussion draft on the tax treaty entitlement of non-CIV funds, such as private equity funds, pension funds, REITS, and sovereign wealth funds.

Commentators had been invited to respond to specific questions included in a March 24 consultation document regarding the impact on non-CIV funds of provisions in the final report on action 6 of the OECD/G20 base erosion profit shifting (BEPS) plan, which concerns the prevention of tax treaty abuse and treaty shopping.

Specifically, the consultation focused on the impact on non-CIV funds of action 6 rules on limitation on benefits, the principal purpose test, the anti-conduit rules, and special tax regimes.

The consultation document and the responses received will be discussed at the May 2016 meeting of Working Party 1 of the OECD Committee on Fiscal Affairs, the OECD said.

See:

• Public Comments

Related MNE Tax articles:

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