The OECD has released details of the framework for peer reviews of the Action 6 standard on preventing the granting of treaty benefits in inappropriate circumstances, a measure which 6 is designed to eliminate double taxation without creating opportunities for non-taxation or reduced taxation through tax evasion or avoidance, including through treaty shopping arrangements.

Each jurisdiction will have to submit details of all existing comprehensive tax treaties on income taxes in force and in effect at 30 June 2018. They will also have to provide proof that they are signed up to the multilateral instrument.

The peer monitoring process will result in publication of annual reports reviewing the effectiveness of implementation and general compliance by OECD members to of the minimum standard. It will also name any jurisdictions which fail to implement the rules and stop abusive tax avoidance and evasion.

Compliance reports will be published annually from January 2019.

The BEPS 6 document includes the terms of reference which sets out the criteria for assessing the implementation of the Action 6 minimum standard, and the methodology for the review.

The Action 6 minimum standard is one of the four BEPS core standards. Each of the four BEPS minimum standards is subject to peer review in order to ensure timely and accurate implementation and thus safeguard the level playing field. All members of the inclusive framework on BEPS commit to implementing the minimum standards and participating in the peer reviews.

The BEPS Action 6 Preventing the Granting of Treaty Benefits in Inappropriate Circumstances peer review document is available here