The OECD has published the comments received on the discussion draft on the follow-up work regarding the interaction between the tax treaty provisions of the report on BEPS Action 6 and the treaty entitlement of non-CIV funds. In particular, the discussion draft provides three examples for comment on the application of the principal purposes test (PPT) rule included in the Report on Action 6 with respect to common transactions involving non-CIV funds.
Click the following links for the discu…