The OECD’s final BEPS Action Plan 6 (“AP6”) report in 2015 on “The Granting of Treaty Benefits in Inappropriate Circumstances” deferred until 2016 the detailed consideration of the application of changes under AP6 for non-CIVs, being Pension Funds, Sovereign Wealth Funds and Managed Funds (“Funds”) investing into alternative assets such as infrastructure, private equity and real estate.
This process is now moving forward and we expect the OECD to release a consultation document shortly, with comments due in April 2016. Clarification of guidance is due to be released in the second half of 2016. AP6 will be a key consideration when it comes to performing due diligence on target groups’ tax affairs and structuring transactions.
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