Prevention of Tax Treaty Abuse – Fourth Peer Review Report on Treaty Shopping
Inclusive Framework on BEPS: Action 6
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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 fourth 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 each of the 139 members of the OECD/G20 Inclusive Framework on BEPS on 31 May 2021, and also contains the jurisdictional section for each member. This is the first peer review process governed by a revised peer review methodology.
Also available in: French
Difficulties in implementing the minimum standard
The peer review provides jurisdictions that encounter difficulties in reaching agreement with another jurisdiction to implement the Action 6 minimum standard with an opportunity to raise concerns with the OECD Secretariat. This process, which is set out in paragraph 35 of the Revised Peer Review Documents, was initially put in place in the 2017 Peer Review Documents (paragraph 19) to identify cases where a jurisdiction is facing a treaty partner that is a member of the Inclusive Framework that is unwilling to respect its commitment to implement the minimum standard. The process was examined as part of the review of the peer review methodology, and it was determined that the process was adequate as it stood and no changes were needed.
Also available in: French
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