Abstract
Action 6 of the BEPS Action Plan identified treaty abuse, and in particular Treaty Shopping, as one of the most important sources of BEPS concerns. In September 2014 the OECD has issued the deliverable for action 6 that consists of three parts: (1) development of model treaty provisions and recommendations regarding the design of domestic rules to prevent the granting of treaty benefits in inappropriate circumstances, (2) clarification that tax treaties are not intended to be used to generate double non-taxation, and (3) identification of tax policy considerations that countries should consider before entering into tax treaties. In this contribution the authors critically analyse the OECD's output on action 6.
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