Prevention of Tax Treaty Abuse – Third Peer Review Report on Treaty Shopping
Inclusive Framework on BEPS: Action 6
This week finance ministers from the G20 group of the world’s largest economies are exploring a global minimum tax on corporate profits, as part of a wider overhaul of the way international businesses are taxed, amid growing international consensus on tackling avoidance after the COVID – 19 pandemic.
In our article dated November 5, 2020 we informed you about reports in the media that the negotiations between Russia and the Netherlands on amendments to the double tax treaty between the two countries had reached an impasse. There have now been relevant developments from both the Russian and the Dutch side.
The determination of tax residency of a company it is very important because they will determine: (a) the state which has taxing rights over the company and (b) the entitlement of tax treaty benefits under a bilateral double tax treaty.