Prevention of Treaty Abuse – Second Peer Review Report on Treaty Shopping
Inclusive Framework on BEPS: Action 6
The 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 members
of the OECD/G20 Inclusive Framework on BEPS (Inclusive Framework) have committed to
implement. This report reflects the outcome of the second peer review of the implementation
of the Action 6 minimum standard on treaty shopping as approved by the Inclusive Framework.
It includes the aggregate results of the review and data on tax treaties concluded
by each of the 129 members of the Inclusive Framework on 30 June 2019 and it contains
the jurisdictional section for each member (see Annex 2). The data compiled for this
peer review demonstrate that the MLI has been the tool used by the vast majority of
jurisdictions that have begun to implement the minimum standard and that the MLI’s
impact is expected to increase quickly as jurisdictions ratify it.
Published on March 24, 2020Also available in: French