The Organisation for Economic Cooperation and Development today released a consultation document outlining issues and requesting comments and suggestions concerning treaty benefits for non-CIV (collective investment vehicle) funds. The consultation document is released as part of the OECD’s follow-up work to Action 6 of the base erosion and profit shifting (BEPS) project.
Today’s OECD release explains that the final report under BEPS Action 6 (“preventing the granting of treaty benefits in inappropriate circumstances”) indicated that the OECD will continue to examine issues related to the treaty entitlement of non-CIV funds so that new treaty provisions included in the BEPS Action 6 report adequately address the appropriate treaty treatment of these funds. The consultation document includes a number of specific questions related to concerns that were identified in comments received on previous discussion drafts related to the BEPS Action 6 report—i.e., concerns as to how the new provisions could affect the treaty entitlement of non-CIV funds as well as possible ways of addressing these concerns.
Comments to the specific questions included in the consultation document, as well as additional suggestions, are requested to be submitted by 22 April 2016.
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