Prevention of Treaty Abuse - Peer Review Report on Treaty Shopping
Inclusive Framework on BEPS: Action 6
BEPS Action 6 minimum standard on preventing the granting of treaty benefits in inappropriate
circumstances, is one of the four BEPS minimum standards that all Inclusive Framework
members have committed to implement.
This report reflects the outcome of the first peer review of the implementation of
the Action 6 minimum standard on treaty shopping as approved by the Inclusive Framework
on BEPS. It includes the aggregate results of the review and data on tax treaties
concluded by each of the 116 members of the Inclusive Framework on BEPS on 30 June
2018. Chapter 1 provides context of the Action 6 minimum standard, Chapter 2 focuses
on the peer review process, Chapter 3 highlights the aggregate results of the peer
review and Chapter 4 presents the conclusions and next steps. The annex contains the
jurisdictional section for each members of the BEPS Inclusive Framework.
Published on February 14, 2019Also available in: French