Page 329 - International Taxation IRS Training Guides

BEPS Reports (Cont’d)

Countering Harmful Tax Practices More
 Action 5:
Taking into Account Transparency and
Effectively,

Substance

• Minimum Standard: Peer
review of preferential tax regimes and
compulsory
spontaneous exchange of certain tax rulings

 Action 6: Preventing the Granting of Treaty Benefits

in Inappropriate Circumstances

• Minimum
Standard: Peer review of tax treaty provisions to prevent
treaty
abuse

Avoidance of
 Action 7: Preventing the Artificial
Status
Permanent Establishment

Aligning Transfer Pricing Outcomes
 Actions 8-10:

with Value Creation

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