OECD publishes public comments on BEPS Actions 6 and 7


In October and November, interested parties were invited to comment on discussion drafts for BEPS Action 6 (Prevention of treaty abuse) and Action 7 (Preventing Artificial Avoidance of PE Status).


Action 6 comments run to nearly 800 pages and includes comments from 79 companies and representative bodies from across a broad range of sectors. A derivative benefits test appears to be a must but there are concerns raised about CIVs. A public consultation will be held by the OECD on 22 January and can be viewed live online (no registration required).


Action 7 comments outstrip that of the preceeding action point with 98 organisations providing comment. The number of large corporations commenting on Action 7 demonstrates the concerns around the practical implications of broadening the definition of permanent establishment. Issues around economic substance, the increased complexity of the compliance burden and uncertainty  persist. A public consultation on Action 7 will take place on 21 January and can be viewed live online (no registration required).

The above items will be discussed at the UK Branch Meeting in London on Wednesday 14 January. There is still time to register for those that have not yet done so. Event begins at 18:00


Register here or email jay.abai@istructuring.com

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