On 6 April 2016, the OECD published comments received on a discussion draft on the treaty residence of pension funds that was issued in February 2016 as part of the follow-up work for BEPS Project Action 6 (Preventing the Granting of Treaty Benefits in Inappropriate Circumstances). The discussion draft includes draft changes to Articles 3 (General Definitions) and 4 (Resident) of the OECD Model Tax Convention, and the commentary for those articles, that will ensure that a pension fund is cons…