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OECD - Base Erosion & Profit Shifting

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Chapter 8

OECD and G20 BEPS Action Plan: Changes to the International Tax System

• The (BEPS) Project, an ambitious plan undertaken jointly by the OECD and G20 to overhaul the global international tax system, culminated with a huge report of recommendations that, if adopted, could have a significant impact on cross-border trade.

Prevent Treaty Abuse

Develop model treaty provisions and recommendations regarding

• the design of domestic rules to prevent the granting of treaty benefits in inappropriate circumstances.


• Work will also be done to clarify that tax treaties are not intended to be used to generate double non-taxation and


• to identify the tax policy considerations that, in general, countries should consider before deciding to enter into a tax treaty with another country. The work will be co-ordinated with the work on hybrids

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