On 2 February 2017 the CFE Fiscal Committee submitted the folowing Opinion Statement in response to an OECD Public Consultation entitled:
'Interaction between the tax treaty provisions of the report on BEPS Action 6 and the treaty entitlement of non-CIV funds'
The Discussion Draft includes three draft examples with regard to the treaty entitlement of non-CIV Funds when applying the principle purpose test (hereinafter “PPT”) as described in the BEPS Action 6 final report. The CFE response provides comments on these three draft examples.
The CFE Response is available here.