OECD Issues Follow-up Consultation on Treaty Benefits for non-CIV Funds as Part of Action 6 of the BEPS Project

On 24 March 2016, the OECD issued a public discussion draft on the tax treaty entitlement of non-CIV (Collective Investment Vehicle) funds. The consultation is part of the follow-up work for BEPS Project Action 6 (Preventing the Granting of Treaty Benefits in Inappropriate Circumstances). It includes a number of specific questions related to previously identified concerns on how the new provisions included in the Action 6 Report could affect the treaty entitlement of non-CIV funds, as well as…