The Organisation for Economic Cooperation and Development (OECD) today released comments received with respect to a discussion draft of proposed changes to the rules concerning the treaty residence of pension funds.
Under the OECD’s base erosion and profit shifting (BEPS) project, a provision of BEPS Action 6 (preventing the granting of treaty benefits in inappropriate circumstances) provides additional work was required to the OECD Model Tax Convention, for a pension fund to be considered to be a resident of the country where the fund is constituted—regardless of whether that pension fund benefits from a limited or complete exemption from taxation in that country. In February 2016, the OECD released for comment a discussion draft with proposed changes to Articles 3 and 4 of the OECD Model Tax Convention to reflect this goal.
Read today’s OECD release.
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