OECD releases discussion draft on the treaty residence of pension funds

Earlier on this year, the OECD published a discussion draft that includes proposals for changes to the OECD Model Tax Convention concerning the treaty residence of pension funds.  The discussion draft, that follows the final report of BEPS Action Plan Number 6, on the granting of treaty benefits in inappropriate circumstances, includes draft changes to […]

Written By ACT Team

On May 12, 2016
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Earlier on this year, the OECD published a discussion draft that includes proposals for changes to the OECD Model Tax Convention concerning the treaty residence of pension funds.  The discussion draft, that follows the final report of BEPS Action Plan Number 6, on the granting of treaty benefits in inappropriate circumstances, includes draft changes to Articles 3 and 4 of the OECD Model Tax Convention, and to the Commentary on these Articles, that aim at ensuring that a pension fund is considered to be a resident of the State in which it is constituted for the purposes of tax treaties.

The draft and comments received will be discussed during a meeting of the OECD Working Party 1 to be held in May.

How can we help?  

For further information, please contact one of the firm’s tax partners, Stephen Balzan on [email protected] or Elaine Camilleri [email protected]. ACT can help you understand the changes to the tax rules and how these can impact your business.  

Apart from its offices in St. Julian’s Malta, ACT operates from a second office in Gozo, which is situated in the capital city of Victoria.  For an appointment in our Gozo office, please call on 00356 21378672 or send us an email on [email protected].