United States - Comparison of the Proposed Changes to the OECD and US Model Conventions
- United States
- P. Carman
- Finance and Capital Markets (formerly Derivatives & Financial Instruments), 2015 (Volume 17), No 6
- 13 November 2015
The author considers recently proposed changes to the US Model Convention, contrasting them with OECD proposals that are part of the Base Erosion and Profit Shifting project. Particular attention is given the introduction under BEPS Action 6 of a limitation on benefits clause, a principal purpose text and a rule dealing with the application of treaties to branches in third countries.