Easily Replace Cross Out Option from the Tax Agreement

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How does Action 6 prevent treaty abuse?

BEPS Action 6 addresses treaty shopping through treaty provisions whose adoption forms part of a minimum standard that members of the BEPS Inclusive Framework have agreed to implement. It also includes specific rules and recommendations to address other forms of treaty abuse.

What are the 4 BEPS minimum standards?

The BEPS 4 minimumstandards that should be implemented are countering ofharmful tax practices and exchange of rulings (Action 5),preventing of treaty abuse (Action 6), re-examining trans-fer pricing documentation including country by countryreporting (Action 13), and enhancing resolution of dis-putes (Action 14).

What is the minimum standard of the Action 5 report?

The Action 5 Report (OECD, 2015) is one of the four BEPS minimum standards. It involves two distinct aspects: a review of certain preferential tax regimes and substantial activities in no or only nominal tax jurisdictions to ensure they are not harmful, and the transparency framework.

What is the OECD Action Plan 6?

Preventing treaty abuse (Action 6) Taxpayers engaged in treaty shopping and other treaty abuse strategies undermine tax sovereignty by claiming treaty benefits in situations where these benefits were not intended to be granted, thereby depriving countries of tax revenues.

What are the minimum standards for the inclusive framework?

The 4 BEPS Minimum Standards to which the members of the Inclusive Framework must conform are: BEPS Action 5 - Combat harmful tax practices [read] BEPS Action 6 - Preventing the Granting of Treaty Benefits in Inappropriate Circumstances [read] BEPS Action 13 - Guidance on Country-by-Country Reporting [read]

What is the action 6 minimum standard?

The Action 6 minimum standard requires jurisdictions to commit to include in their tax treaties provisions dealing with treaty shopping to ensure a minimum level of protection against treaty abuse.

What is an agreement to avoid double taxation?

A DTA is therefore a contract signed by two countries (referred to as the contracting states) to avoid or alleviate (minimise) territorial double taxation of the same income by the two countries.

What is an example of base erosion and profit shifting?

Base erosion refers to the practice of reducing the taxable base. An example is deducting large interest payments in order to lower the taxable profits. Profit shifting refers to the practice of shifting taxable profits from high-tax countries to low-tax countries.

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Replace Cross Out Option from the Tax Agreement