The OECD has published stakeholder responses to its discussion draft on Action Point 6 of the BEPS Action Plan, which deals with treaty abuse. Funds and asset managers are calling for disparate treatment of collective investment vehicles (CIVs), while others are urging the OECD to reconsider its treaty preamble.
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The new guidance is not meant to reflect a substantial change to UK law, but the requirement that tax advice is ‘likely to be correct’ imposes unrealistic expectations
China and a clutch of EU nations have voiced dissent after Estonia shot down the US side-by-side deal; in other news, HMRC has awarded companies contracts to help close the tax gap