• 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. See EY Global Tax Alert, OECD releases first annual peer review report on Action 5, dated 5 December 2017. 5.1 Approach number of BEPS Actions to each other, and since the BEPS-project is a huge and ambitious project of the OECD, this research may show how closely connected this huge project actually is. The methodology used to perform the research consists of various steps.

Beps action 6 three-pronged approach

The goal of Action 6 is to prevent the granting of treaty benefits in inappropriate circumstances. It needs to be made clear that tax treaties are not intended to be used to generate double non-taxation. In addition, countries should consider this before entering into a tax treaty with another country. OECD has recommended the following three pronged approach: Clarification in treaty title and preamble (Section B of the final report); Inclusion of a specific anti-abuse rule based on a draft U.S. style limitation-on-benefits (LOB) provisions; Addition of a more general anti-abuse rule 1. The General Anti-Abuse Rule and BEPS Action 6 Action 6 of the BEPS initiative has the following three pur - poses: (1) preventing the granting of treaty benefits in inappro - priate circumstances; (2) clarifying that tax treaties are not intended to be used to generate double non-taxation; and Beginning with tax treaty shopping, the Final Report of BEPS Action 6 recommends a “three-pronged approach” comprising the following elements: • a “clear statement” in tax treaties that “the Contracting States, when entering into a treaty, wish to prevent tax avoidance and, in particular, intend to avoid received further impetus through the G20/OECD Base e rosion and p rofit shifting action plan (known as BEPS).

3. See EY Global Tax Alert, OECD releases progress report on preferential regimes Action 6. Prevention of tax treaty abuse.

The OECD did extensive research on this subject, to which extent they consulted the public twice3, which resulted in a final report on Action 7 in October 2015.4 Previous to the BEPS-project, the OECD BEPS Action 8, 9 and 10 Assure that transfer pricing outcomes are in line with value creation Action 8: Intangibles Page 6 New TP approach for intangibles . The BEPS report, previously released, and the new Action Plan are available for public review, with many commentators already providing insight on the Action Plan. The 24 month Action Plan is comprehensive and aggressive, with tax transparency and disclosure rules likely to be implemented early in that timeline.

Erosion and Profit Shifting (BEPS) Action Plan and what they Action 6: Prevent treaty abuse. Action 7: The OECD recommended a three-tiered approach to. The basic framework of Action 6 is based on a three- pronged approach to be used by countries to release new treaties or to modify existing ones: 1. a clear Although recommending this three-pronged approach to tax treaty shopping, the final report on BEPS action 6 acknowledges that states might have legitimate.

Such is the case with the OECD’s approach to non-collective investment vehicle funds (non-CIV funds) and their interaction with the BEPS Action 6 on preventing the granting of treaty benefits in inappropriate circumstances. Action 6 refresher Action 6: Preventing the Granting of Treaty benefits in inappropriate circumstances The BEPS Action Plan had identified treaty abuse and treaty shopping as one of the most important sources of BEPS concerns. 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 .
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Action 6 of BEPS introduced the principal purpose test (PPT) as one of the Minimum Standards to be implemented by the countries participating in the BEPS Inclusive Framework. The PPT has been also introduced in the Multilateral Instrument (MLI) in force since 1 July 2018.

BEPS action plans may impact the businesses of Indian Multinational Enterprises [MNEs].
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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 4: Interest Deductions.

See EY Global Tax Alert, OECD releases first annual peer review report (Phase 1) on Action 13, dated 29 May 2018. See EY Global Tax alert, OECD releases outcomes of the second phase of peer reviews on BEPS Action 13 1.

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. See EY Global Tax Alert, OECD releases first annual peer review report on Action 5, dated 5 December 2017. 5.1 Approach number of BEPS Actions to each other, and since the BEPS-project is a huge and ambitious project of the OECD, this research may show how closely connected this huge project actually is.