THE OECD has released the BEPS Consultation paper
on treaty entitlement of non-CIV funds. It has invited responses to the
questions contained in the paper.
Paragraph 14 of the final version of the Report on Action 6 of the BEPS Action
Plan (Preventing the Granting of Treaty Benefits in Inappropriate Circumstances)
indicates that the OECD will continue to examine issues related to the treaty
entitlement of non-CIV funds in order to ensure that the new treaty provisions
included in the BEPS Action 6 Report address adequately the treaty entitlement
of these funds.
This consultation document has been produced as part of the follow-up work
on this issue. It includes a number of specific questions related to concerns,
identified in comments received on previous discussion drafts related to the
BEPS Action 6 Report, as to how the new provisions included in the BEPS Action
6 Report could affect the treaty entitlement of non-CIV funds as well as to
possible ways of addressing these concerns that were suggested in these comments
or subsequently.
Commentators
have been invited to respond to the specific questions included in this consultation
document in order to facilitate the analysis of these concerns and suggestions.
Commentators may also offer additional suggestions. Since a number of questions
are likely to be relevant only for commentators who supported specific approaches,
it is expected that most commentators will only address some of the questions.
The consultation document and the responses received will be discussed at
the May 2016 meeting of Working Party 1 of the OECD Committee on Fiscal Affairs.
Responses
should be sent by 22 April 2016 at the latest by e-mail to taxtreaties@oecd.org
in Word format.
They should be addressed to the Tax Treaties, Transfer Pricing and Financial
Transactions Division, OECD/CTPA.
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