The exchange of tax information has received ample attention recently, due to a number of recent headlines on aggressive tax planning and tax evasion. Whilst both participating tax authorities will gain when foreign investments (FDI) are bilateral, we demonstrate that FDI receiving nations will...

The OECD's public discussion draft ‘BEPS Action 6: Preventing the Granting of Treaty Benefits in Inappropriate Circumstances' proposed a series of rules for the OECD model. The draft for Article X, ‘‘Entitlement to Benefits,'' the first five paragraphs of which are described therein as...