Matthew D Saronson and Ceinwen Rees (Debevoise & Plimpton) examine the application of new anti-treaty abuse provisions to private equity fund structures.
Readers or watchers of Agatha Christie’s Murder on the Orient will know that anything involving group action is more complex and takes time to work out. Such is the case with the OECD’s approach to non-collective investment vehicle funds (non-CIV funds) and their interaction with the BEPS Action 6 on preventing the granting of treaty benefits in inappropriate circumstances.
Action 6 refresher
Action 6 as set out by Michael McGowan and Andrew Thomson (‘BEPS: preventing treaty abuse’ Tax Journal 31 October 2015) is about preventing treaty abuse. This will be achieved via the inclusion in double tax treaties of:
a clear statement that the treaty’s aim is the prevention of tax avoidance; and
some combination of a limitation on benefits (LoB) rule...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
Matthew D Saronson and Ceinwen Rees (Debevoise & Plimpton) examine the application of new anti-treaty abuse provisions to private equity fund structures.
Readers or watchers of Agatha Christie’s Murder on the Orient will know that anything involving group action is more complex and takes time to work out. Such is the case with the OECD’s approach to non-collective investment vehicle funds (non-CIV funds) and their interaction with the BEPS Action 6 on preventing the granting of treaty benefits in inappropriate circumstances.
Action 6 refresher
Action 6 as set out by Michael McGowan and Andrew Thomson (‘BEPS: preventing treaty abuse’ Tax Journal 31 October 2015) is about preventing treaty abuse. This will be achieved via the inclusion in double tax treaties of:
a clear statement that the treaty’s aim is the prevention of tax avoidance; and
some combination of a limitation on benefits (LoB) rule...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
