DAY 1: BEPS Action 6: Treaty Abuse OECD-BEPS Project EU developments: list of non-cooperative jurisdictions and standard of good governance in tax matters BEPS Action 6: Terms of reference BEPS Action 6 and MLI Practical problems application PPT DAY 2: Relationship PPT and domestic GAARs and SAARs and practical cases

BEPS Action 13 has been implemented by the Program Law of July 1, 2016 and published in the Belgian Official Gazette of July 4, 2016. The legislation to introduce changes in the tax law further to BEPS Action 2 (Hybrids), 3 (Controlled Foreign Corporations), 4 (Interest deductions), 7 (Permanent Establishment) and

The amending protocol contains the new preamble language that clarifies that the tax treaty is not intended to be used to generate double non-taxation or reduced taxation through tax evasion and avoidance. limitation on benefits provisions; and (iii) a detailed limitation-on-benefits (LOB) with anti-abuse measures to counteract conduit financing.11 Since the principal purpose test has been adopted by most of the countries, i.e., 136 of the 137 jurisdictions of the BEPS Inclusive Framework, and one country (Cyprus) which is only a The G20/OECD Base Erosion and Profit Shifting Package - Assessment by the TUAC Secretariat 2 I. Overview 1. On October 5th 2015, the OECD delivered the final set of measures and recommendations on tackling aggressive corporate tax planning, thereby completing the first phase of the 15-point • OECD’s BEPS Action Plans - a project developed by OECD / G20 Member Countries - 12 June 2019) MLI Notified by Ministry of Finance. 9 August 2019. • Targets abusive arrangements entered into with the main purpose of obtaining a tax benefit. GAAR.

Beps action 12 main benefit test

This paper aims tems around the world, which is one of the purposes of the BEPS Action Plan. PPT. Principal Purpose Test 45 Revised discussion draft on BEPS Action 7, 15 maj till 12 juni 2015, s.

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Furthermore, certain hallmarks must also fulfill a ‘main benefit test’ before a cross-border arrangement must be reported. 4.1.1 The main benefit test The main benefit test is met if it can be established that the main benefit or one of the main benefits which, having regard to all relevant facts and circumstances, a person may reasonably expect to derive from an arrangement is the obtaining of a tax advantage. The main benefit test is broader than existing general DAC6 can trace its genesis from the BEPS Action 12 which provides recommendations for the design of rules to require taxpayers and advisors to disclose aggressive tax planning arrangements. To determine whether an arrangement should be reported, the Directive has included Hallmarks.

10 Sep 2019 certain notions such as the main benefit test, the commentaries of the bill of law explicitly refer to the BEPS Action 12 Final Report. In the latter

BEPS Action 14: OECD releases stage 1 peer review reports on dispute Department for Enterprise manages the diversified economy in 12 key sectors. "BBC News - Manx charities to benefit from lottery" .

Urban Nilsson the significantly dry and hot summer led to the main finding that the knowledge will have to be tested in practice, which is in scope for his knowledge on cellular metabolism will also benefit the for European Cost Action. Out of the shtetl as the main nerve of Soviet Jewish cultural history, and its repercussions today About 12 million animals are used in animal testing, in Europe only. 2010 version (OECD Guidelines), and OECDs new guidance from the BEPS in the forms of cultural peculiarities, local solidarities, and political action. 6 BEPS-projektet 5 oktober 2015: 13 rapporter för 15 Actions Åtgärder för att 12 Action 5 Skadliga skatteregimer Minimistandard Granskning av och PPT-regler (limitation on benefits-regel och principal purpose test) i nya 12 OECD (2015), Preventing the Granting of Treaty Benefits in Inappropriate är en limitation of benefit-regel (LOBregel), en principal purpose test (PPT-regel) OECD Productivity Working. Papers, 2018-12. Criscuolo, C. och J. Timmis (2018b). GVCs and Productivity: Are Hubs.
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Main benefit test There is an additional test that is relevant for: guidance might be useful) with the the generic hallmarks (set out in section A), the first category of specific hallmarks (in section B) that covers circular transactions, use of losses and income conversion, BEPS Action 12: Mandatory disclosure rules Response by the Chartered Institute of Taxation 1 Introduction 1.1 The Chartered Institute of Taxation (CIOT) is pleased to respond to the Public discussion draft published on 31 March 2015 on BEPS Action 12: Mandatory disclosure rules (Discussion Draft). By means of the principal purpose test, the tax administration can deny the tax treaty benefit if one of the principal purposes of the action undertaken by the taxpayer was to obtain a benefit. This principal purpose test has been developed by the OECD with the political support of the G20 as one of the actions to tackle Base Erosion and Profit Shifting by multinationals (BEPS Project).

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The OECD BEPS Action 6 report contains a principal pur-pose test rule (PPT rule) for the purpose of combating abuse of tax treaties. This PPT rule is also included in the OECD Multilateral Instrument. The PPT rule is (amongst others) applicable when ‘it is rea-sonable to conclude’ that a benefit (granted by a tax treaty)

Applying the anti-abuse provisions to a fund is tricky. One approach, the Limitation-on-benefits (LoB) rule, involves tracing through to all of the beneficial owners to establish whether they are obtaining better treaty benefits by investing through the fund. Overview of BEPS Action Report 6 • BEPS Action Report 6 provides 3 alternative rules to address treaty abuse • As a minimum standard, it requires countries to implement at least one of the following anti-abuse measures in their tax treaties: ‒ a Principal Purpose Test (‘PPT’)only; 2018-10-02 Preventing the Granting of Treaty Benefits in Inappropriate Circumstances Addressing base erosion and profit shifting is a key priority of governments around the globe. In 2013, OECD and G20 countries, working together on an equal footing, adopted a 15-point Action Plan to address BEPS. This report is an output of Action 6.