Prevention of Tax Treaty Abuse – Fifth Peer Review Report on Treaty Shopping
Inclusive Framework on BEPS: Action 6
Under the BEPS Action 6 minimum standard on treaty shopping, members of the OECD/G20 Inclusive Framework on BEPS have committed to strengthen their tax treaties by implementing anti-abuse measures. This report reflects the outcome of the fifth peer review of the implementation of the BEPS Action 6 minimum standard on treaty shopping. It includes the aggregate results of the review and data on tax treaties concluded by the members of the OECD/G20 Inclusive Framework on BEPS as of 31 May 2022, as well as jurisdictional sections which contain detailed information for each member jurisdiction.
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Foreword
Digitalisation and globalisation have had a profound impact on economies and the lives of people around the world, and this impact has only accelerated in the 21st century. These changes have brought with them challenges to the rules for taxing international business income, which have prevailed for more than a hundred years and created opportunities for base erosion and profit shifting (BEPS), requiring bold moves by policy makers to restore confidence in the system and ensure that profits are taxed where economic activities take place and value is created.
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