The Organisation for Economic Cooperation and Development (OECD) on 18 December 2017 released the latest edition of its Model Tax Convention incorporating various changes developed under the OECD/G20 project to address base erosion and profit shifting (BEPS).
These measures include Action 2 (Neutralising the Effects of Hybrid Mismatch Arrangements), Action 6 (Preventing the Granting of Treaty Benefits in Inappropriate Circumstances), Action 7 (Preventing the Artificial Avoidance of Permanent Establishment Status) and Action 14 (Making Dispute Resolution More Effective).
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