1945

Tax avoidance strategies aimed at obtaining treaty benefits are an important concern for most countries but are particularly problematic for developing countries that have limited experience in dealing with sophisticated tax-avoidance strategies. Tax treaty negotiators should be aware of these concerns and of the ways of addressing these strategies through tax treaty provisions or other mechanisms. A detailed discussion of tax avoidance strategies aimed at obtaining treaty benefits and of ways of addressing them is included in the section “Improper use of tax treaties” in the Commentary on Article 1 of the UN Model. That discussion takes account of the various changes that were made in 2017 to the UN and OECD models in order to address some of these strategies. These changes, which are discussed in section III under the relevant articles of the UN Model, resulted primarily from the reports on Action 6 (Preventing the Granting of Treaty Benefits in Inappropriate Circumstances, Action 6—2015, Final Report ) and Action 7 (Preventing the Artificial Avoidance of Permanent Establishment Status, Action 7—2015 Final Report) of the G20/ OECD project.

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