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BEPS Public Consultation: Prevent treaty abuse
A public consultation on follow-up work on BEPS Action 6 (Prevent treaty abuse) is scheduled to be held in Paris at the OECD Conference Centre on 22 January 2015.
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Release of a revised discussion draft on BEPS Action 6 (Prevent Treaty Abuse)
Public comments are invited on a new discussion draft which includes proposals on how to deal with the follow-up work on Action 6 (Prevent Treaty Abuse) of the Action Plan on Base Erosion and Profit Shifting (BEPS).
treaty
Public comments received on revised discussion draft on follow-up work on BEPS Action 6 (Prevent treaty abuse)
On 22 May 2015, interested parties were invited to comment on a revised discussion draft which includes proposals on how to deal with the follow-up work on Action 6 (Prevent treaty abuse) of the BEPS Action Plan.
treaty
OECD releases discussion draft on the treaty residence of pension funds
Public comments are invited on a discussion draft that includes proposals for changes to the OECD Model Tax Convention concerning the treaty residence of pension funds. Comments should be sent by 1 April 2016 at the latest.
treaty
OECD releases a BEPS consultation document on the treaty entitlement of non-CIV funds
Responses are invited to the questions included in a consultation document on issues and suggestions related to the impact of the Report on BEPS Action 6 on the tax treaty entitlement of non-CIV funds.
treaty
Public comments received on discussion draft on the treaty residence of pension funds
On 29/02/2016, interested parties were invited to comment on a discussion draft othat includes proposals for changes to the OECD Model Tax Convention concerning the treaty residence of pension funds. The OECD is grateful to the commentators for their input and now publishes the comments received.
treaty
Public comments received on discussion draft on treaty entitlement of non-CIV funds
On 24 March 2016, comments were invited to the questions included in a consultation document on issues and suggestions on the tax treaty entitlement of non-CIV (Collective Investment Vehicle) funds.
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OECD releases discussion draft on the multilateral instrument to implement the tax-treaty related BEPS measures
Public comments are invited on technical issues identified in a request for input related to the development of a multilateral instrument to implement the tax-treaty related BEPS measures. Comments should be sent by 30 June 2016 at the latest.
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OECD appoints new Head of the Tax Treaty, Transfer Pricing & Financial Transactions Division in the Centre for Tax Policy and Administration
Mr Jefferson VanderWolk has been appointed Head of the Tax Treaty, Transfer Pricing & Financial Transactions Division in the Centre for Tax Policy and Administration. He will take up his duties in early July 2016.
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Public comments received for the discussion draft on the development of a multilateral instrument to implement the tax treaty related BEPS measures
On 31 May 2016, public comments were invited on technical issues identified in a Request for Input related to the development of a multilateral instrument to implement the tax-treaty related BEPS measures. This document compiles the comments received in response to that request for input.
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Public consultation on the multilateral instrument to implement the tax-treaty related BEPS measures
The OECD will hold a public consultation event on the Multilateral Instrument on 7 July 2016 at the OECD Conference Centre in Paris, France.
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Countries adopt multilateral convention to close tax treaty loopholes and improve functioning of international tax system
More than 100 jurisdictions have concluded negotiations on a multilateral instrument that will swiftly implement a series of tax treaty measures to update international tax rules and lessen the opportunity for tax avoidance by multinational enterprises.
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Interaction between the tax treaty provisions of the report on BEPS Action 6 and the treaty entitlement of non-CIV funds
Comments are invited on draft examples included in a discussion draft on the follow-up work on the ineraction between the treaty provisions of the report on BEPS Action 6 and the treaty entitlement of non-CIV funds.
treaty
Public comments received on draft examples prepared as part of the follow-up work on the interaction between the treaty provisions of the report on BEPS Action 6 and the treaty entitlement of non-CIV funds
On 6 January 2017, public comments were invited on draft examples prepared as part of the follow-up work on the interaction between the treaty provisions of the report on BEPS Action 6 and the treaty entitlement of non-CIV funds. The OECD is grateful for the input and now publishes a compilation of the comments received.
treaty
The United Arab Emirates become the 109th jurisdiction to join the most powerful multilateral treaty against offshore tax evasion and avoidance
His Excellency Muadid Hareb Mughair Al-Khaili, Ambassador of the United Arab Emirates to France, signed the Multilateral Convention on Mutual Administrative Assistance in Tax Matters in the presence of the OECD Deputy Secretary-General, Rintaro Tamaki.
treaty
New head appointed for OECD tax treaty unit
Sophie Chatel has been appointed Head of the Tax Treaty Unit in the Centre for Tax Policy and Administration. She will take up her duties on 6 September 2017.
treaty
Further progress made in implementation of BEPS measures against tax treaty abuse
Today, Jersey deposited its instrument of ratification for the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting ("multilateral convention") with the OECD. Subsequently, on 20 December, Curaçao joined the multilateral convention.
treaty
OECD releases BEPS peer review reports on improving tax dispute resolution mechanisms and preventing treaty shopping
Progress continues with the implementation of the BEPS package, as the OECD releases additional peer review reports assessing countries’ efforts to implement the Action 6 and Action 14 minimum standards as agreed under the OECD/G20 BEPS Project.
treaty
OECD releases second peer review report on preventing treaty shopping (BEPS Action 6)
Progress continues with the implementation of the BEPS package, as the OECD releases the second peer review assessing countries’ efforts to implement the Action 6 minimum standard as agreed under the OECD/G20 BEPS Project.
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Fact finding survey on investment treaty law, sustainable development responsible business conduct
This survey was presented at the Informal ministerial meeting on responsible business conduct held in Paris on 26 June 2014.
treaty
Treaty shopping and tools for investment treaty reform
Paris, 12 March 2018 - The fourth annual OECD Investment Treaty Conference addressed treaty shopping -- a controversial investment treaty issue of policy interest for many governments and stakeholders -- and explored tools to help interested governments improve their investment treaty policies.
treaty
Fact finding survey on investment treaty law, sustainable development responsible business conduct
This survey was presented at the Informal ministerial meeting on responsible business conduct held in Paris on 26 June 2014.
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Investment Treaty Law, Sustainable Development and Responsible Business Conduct: A Fact Finding Survey, International Investment Working Paper 2014/1
Investment treaties are often thought to be silent on investors’ responsibilities to host societies and on their contributions to sustainable development. This paper establishes a factual and statistical basis for understanding the relationship between investment treaty law and governments’ ability to advance the sustainable development agenda and promote responsible business conduct.
treaty
Treaty shopping and tools for investment treaty reform
Paris, 12 March 2018 - The fourth annual OECD Investment Treaty Conference addressed treaty shopping -- a controversial investment treaty issue of policy interest for many governments and stakeholders -- and explored tools to help interested governments improve their investment treaty policies.
treaty
Putin signs law suspending Russia's participation in key nuclear arms control treaty with America
Putin's decree released on Wednesday formalizes Russia's departure from the 1987 Intermediate-Range Nuclear Forces treaty with the United States following Washington's withdrawal.
treaty
Boris Johnson risks Trump row over UK-US extradition treaty
Boris Johnson today risked a major row with Donald Trump after he claimed the UK's extradition arrangements with the US are 'imbalanced'.
treaty
India's pro-asbestos position sets back international treaty
Held in Geneva last month, the Rotterdam Convention was attended by 500 participants from 140 governments, UN organisations, and NGOs. India sided with Canada and few other nations to prevent the listing of chrysotile asbestos,
a known carcinogen.
R Sridhar
has more.
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Non-nuclear peace: beyond the nuclear ban treaty / Tom Sauer, Jorg Kustermans, Barbara Segaert, editors
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Authority and legitimacy of environmental post-treaty rules / Tim Staal
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Arbitration costs: myths and realities in investment treaty arbitration / Susan D. Franck
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Timor Sea Maritime Boundaries Treaty Consequential Amendments Bill 2018 [Provisions], Passenger Movement Charge Amendment (Timor Sea Maritime Boundaries Treaty) Bill 2018 [Provisions] / The Senate Economics Legislation Committee
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Existing treaty could help manage global plastic waste trade, researchers suggest
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Canada - U.S. Tax Treaty: A Practical Interpretation
The Fifth Protocol to the Canada - U.S. Income Tax Treaty has introduced a myriad of changes relating to the rights of both countries to tax income earned by their respective residents. Canada - U.S. Tax Treaty: A Practical Interpretation is an invaluable resource designed to assist practitioners with clients involved in cross-border business activities deal with the complexity and uncertainty of these changes.
CCH Canadian’s Canada - U.S. Tax Treaty: A Practical Interpretation contains the full text of the Canada - U.S. Tax Convention, as amended by the First through Fifth Protocols, with commentary by Dentons following each Article of the Treaty. The commentary provides a detailed analysis of the Fifth Protocol, including:
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Changes to the “tie-breaker” rule for determining the residence of a corporation that qualifies as a resident of both Contracting States
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Entitlement to Treaty benefits for “fiscally transparent entities”
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New permanent establishment rules
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Elimination of withholding tax on certain interest payments
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Taxation of a non-resident’s emigrant gains
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Taxation of “income from employment” earned by non-residents
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Taxation of stock options received by individuals employed in both Canada and the United States
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Introduction of a reciprocal limitation of benefits provision
The Technical Explanations of the Treaty and the Third, Fourth, and Fifth Protocols, as provided by the U.S. Treasury Department, are reproduced, along with a report on the Fifth Protocol by the Joint Committee on Taxation for the U.S. Senate. Other useful resources contained in this edition include:
- Annotations of related Dominion Tax Cases
- Memorandum of Understanding between the Competent Authorities of Canada and the United States Regarding the Mutual Agreement Procedure
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Agreement between the Government of Canada and the Government of the United States of America with Respect to Social Security
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Income Tax Conventions Interpretation Act
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Rates of Withholding Tax under Income Tax Agreements Signed by Canada
If you would like more details about this product, or would like to order a copy online, please click here.