Comments are invited on a discussion draft dealing with the prevention of treaty abuse, as covered by Action 6 of the BEPS Action Plan. The draft deals with follow-up work in relation to the substance of the model provisions, specifically the Limitation on Benefits rule along with the treaty entitlement of collective investment vehicles and non-collective investment vehicles funds. The deadline for submission of comments is 9 January 2015.

Comments are also invited on Draft 10 of BEPS Action Plan. The Action Plan (Action 10) focuses on excessive management fees and head office expenses, seen by the OECD as an erosion of the tax base. The draft identified common intra-group services such as management fees which charge a limited profit mark up on costs. The draft provides for detailed reporting requirements aimed at providing greater transparency on such forms of base eroding payments. The deadline for submission of comments is 14 January 2015. Chartered Accountants Ireland, under CCAB-I, will be responding to the invitations for comment.