In October 2015, the OECD released its final deliverable on Action 6 that is dedicated to prevent the granting of treaty benefits in inappropriate circumstances. In order to determine the most appropriate manner to prevent the granting of treaty benefits, the final deliverable differentiates...

BEPS Action 5 is one of the four minimum standards which all members of the OECD/G20 Inclusive Framework on BEPS have committed to implement. One part of the Action 5 minimum standard is the transparency framework for compulsory spontaneous exchange of information on certain tax rulings which,...

BEPS Action 5 is one of the four minimum standards which all members of the OECD/G20 Inclusive Framework on BEPS have committed to implement. One part of the Action 5 minimum standard is the transparency framework for compulsory spontaneous exchange of information on certain tax rulings which,...