On January 8, 2015, TEI submitted comments to the OECD regarding its BEPS Public Discussion Draft on Follow Up Work on BEPS Action 6: Preventing Treaty Abuse. TEI’s comments reiterated key recommendations from the Institute’s April 2014 on the same subject. These recommendations include TEI’s preference for a limitation on benefits provision to police treaty abuse in the OECD model treaty, the Institute’s opposition to a principal purposes test for policing such abuse, and the need for transition rules for multi-national enterprises that will be impacted by the final changes to the model treaty.
TEI’s comments were prepared under the aegis of TEI’s European Direct Tax Committee, whose chair is Nick Hasenoehrl. Benjamin R. Shreck, TEI Tax Counsel, coordinated the preparation of TEI’s comments.