The BEPS Action Plan identified fifteen actions to address base erosion and profit shifting in a comprehensive manner and set deadlines to implement these actions. 2. The Action Plan recognises that the actions to counter BEPS must be complemented with actions that ensure certainty and predictability for business. OECD BEPS Action Plan: Moving from talk to action in the Americas OECD BEPS Action Plan: Moving from talk to action in the Americas 3 2017 KPMG International Cooperative (KPMG International). KPMG International provides no client services and is a Swiss entity with which the independent member firms of the KPMG network are affiliated.

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8 Published in Government Gazette No. 185553 of 15/12/1997. Action 6 - Treaty Benefits Action 6 identifies treaty abuse, and in particular treaty shopping as one of the most important sources of BEPS concerns. The report suggests that the following three pronged approach be taken to tackle treaty abuse: 1) First, a clear statement in tax treaties that the Contracting States, when entering into a treaty, All rights reserved. 25 OECD – BEPS 2014 Preventing the granting of treaty benefits in inappropriate circumstances Treaty abuse and treaty shopping identified as one of the most important sources of BEPS concerns Three pronged approach recommended to address treaty abuse and shopping arrangements Design rules to prevent granting of treaty benefits in inappropriate circumstances Tax treaties not intended to be used to generate double non-taxation Identification of tax policy consideration Action 14 contains one of only four minimum standards implemented by the BEPS project, on which competent authorities will be externally monitored. This reaffirms the importance of MAP as a principle, both at a treaty level, and in ensuring greater clarity for taxpayers and fellow competent authorities on how each country provides access to MAP and what MAP procedures exist.

transfer pricing The OECD published an Action Plan, which includes 15 action points to address BEPS in a comprehensive manner and sets deadlines to implement these actions. Action Point 6 of the Action Plan aims to prevent the abuse of double taxation agreements ( DTA ) and to develop model DTA provisions and recommendations regarding the design of domestic rules to prevent the granting of DTA benefits in OECD BEPS Action Plan: moving from talk to action in the European region — 2016 Overview The OECD Action Plan on BEPS, introduced in 2013, set out 15 specific action points to ensure international tax rules are fit for an increasingly globalized, digitized business world and to prevent international companies from paying little or no tax. Action 3: Controlled Foreign Companies (CFC) Rules. Seeks to establish a standard definition of a CFC and its income, and proposes rules that eliminate mismatches or holes that allow CFCs to shift income elsewhere.

Action 6 The OECD proposal provides a three-pronged approach: Treaty statement re: anti-avoidance rule and treaty shopping opportunities; Specific anti-abuse rule based on Limitation of Benefit The BEPS Action Plan states that “Treaty abuse is one of the most important sources of BEPS concerns”, and then describes Action 6 as recommended the following “three-pronged approach”: 2015-10-05 BEPS Action 14: Make Dispute Resolution Mechanisms More Effective The Organization for Economic Cooperation and Development on December 18, 2014, must be read in the broader context of the intention to introduce a three-pronged approach designed to represent a step change in the resolution of treaty-related disputes through the MAP. Corporate/International tax–Actions1to7and11, 12,14and15. 6. ActionPlan1–DigitalEconomy Action 1: Addressing the tax challenges of the Digital Economy (‘DE’) • No special tax regime has been prescribed. BEPS measures under other Action Plans seek to address these challenges. • Destination based tax for GST / VAT Indian perspective Impact of BEPS Implementation - there was a fairly broad consensus that 1) the Action 1 VAT recommendations are being widely implemented and that they are having a significant impact on tax collection in market jurisdictions; 2) the BEPS changes are impacting business models (particularly Action 7 encouraging a shift towards buy/sell), and that consistency in business model globally was The MLI also implements the BEPS Action 6 minimum standard by implementing a principal purpose test (PPT). Under the PPT rule, a tax treaty benefit is denied where one of the principal purposes of an arrangement or transaction is to directly or indirectly obtain the benefit, unless the granting of that benefit in the circumstances would be in accordance with the object and purpose of the See EY Global Tax Alert, OECD releases final reports on BEPS Action Plan, dated 6 October 2015.

The 24 month Action Plan is comprehensive and aggressive, with tax transparency and disclosure rules likely to be implemented early in that timeline. Minimum standards are the BEPS recommendations that all members of the Inclusive Framework are committed to implement. These are some of the recommendations included in Action 5 on harmful tax practices, Action 6 on treaty abuse, Action 13 on transfer pricing documentation and CbCR and Action 14 on dispute resolution. The MLI also implements the BEPS Action 6 minimum standard by implementing a principal purpose test (PPT). Under the PPT rule, a tax treaty benefit is denied where one of the principal purposes of an arrangement or transaction is to directly or indirectly obtain the benefit, unless the granting of that benefit in the circumstances would be in accordance with the object and purpose of the beps action plans that are a priority in africa cont. Action Plan 6: Prevent Treaty Abuse Entails “treaty shopping” - use of DTT by the residents of non-treaty country to obtain treaty benefits Actions 8 to 10 of the BEPS Action Plan aim to reinforce this principle by ensuring that the allocation of profits is correctly aligned with the economic activity that produced the profits.
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In order to address these concerns, the task force carried out work to develop model treaty c rules and identify the tax BEPS Project including its four minimum standards (Action 5 on harmful tax practices, Action 6 on treaty abuse, Action 13 on country-by-country reporting and Action 14 on dispute resolution mechanisms). They will also be able to monitor the evolution of the tax raised by the digital economy challenges (Action 1) and Action 10 . Assuring that TP outcomes are in line with value creation (Other high-risk transactions) Action 11 . Establish methodologies to collect and analyze data on BEPS and the actions to address it . Action 12 . Require taxpayers to disclose their aggressive tax planning arrangements .

The BEPS Action Plan includes 15 actions to address BEPS in a comprehensive manner and sets deadlines to implement these actions. 2. The Discussion Draft recommends a three-pronged approach to address situations of treaty shopping: a) Clarify in the title and the preamble of tax treaties that tax treaties are not intended to generate double non-taxation and that the Contracting States intend to prevent tax evasion and avoidance. b) Include in tax treaties a LOB provision based on The Action Plan on Base Erosion and Profit Shifting (“BEPS Action Plan”) identified 15 actions to address BEPS in a comprehensive manner. In October 2015, the G20 Finance Ministers endorsed the BEPS Package, which includes the report on Action 6: Preventing the Granting of Treaty Benefits in Inappropriate Circumstances (“the Report on Action 6” or “the Report”, OECD (2015)).
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BEPS measures under other Action Plans seek to address these challenges. • Destination based tax for GST / VAT Indian perspective Impact of BEPS Implementation - there was a fairly broad consensus that 1) the Action 1 VAT recommendations are being widely implemented and that they are having a significant impact on tax collection in market jurisdictions; 2) the BEPS changes are impacting business models (particularly Action 7 encouraging a shift towards buy/sell), and that consistency in business model globally was The MLI also implements the BEPS Action 6 minimum standard by implementing a principal purpose test (PPT). Under the PPT rule, a tax treaty benefit is denied where one of the principal purposes of an arrangement or transaction is to directly or indirectly obtain the benefit, unless the granting of that benefit in the circumstances would be in accordance with the object and purpose of the See EY Global Tax Alert, OECD releases final reports on BEPS Action Plan, dated 6 October 2015. See EY Global Tax Alert, OECD releases peer review documents on BEPS Action 5 on Harmful Tax Practices and on BEPS Action 13 on Country-by-Country Reporting, dated 6 February 2017.

In relation to Action Item 6, however, this must be addressed in a balanced and efficient manner, allowing the clarity and certainty of Treaty benefits appropriate This report presents the revised peer review documents for the review of the implementation of the BEPS Action 6 minimum standard on treaty shopping. The original peer review documents were approved by Working Party no.
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4 OECD/G20 2015 Final Report on Action 6 in para 19. BEPS Action 6 aims to prevent the granting of treaty benefits in inappropriate circumstances. 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 Action 14: Three-pronged approach Three-pronged approach would consist: • Political commitments to effectively eliminate taxation not in accordance with the OECD Model Tax Convention on Income and on Capital • Provide new measures to improve access to the MAP and improved procedures BEPS presentation -Final - Copy 1. KPMG BEPS Action Plan Informative Discussion CFO India Network 27th November 2014 2. Areas of discussion Tax Morality and Transparency1 3 OECD BEPS Action Plan3 9 Action 1 – Addressing the tax challenges of the digital economy4 15 Action 2 – Neutralizing effects of hybrid mismatch arrangements5 21 Action 6 – Preventing the granting of treaty benefits in