OECD makes positive changes to real estate example in Model Tax Convention

On July 11, in an important step for non-listed real estate investment funds, the OECD released draft contents of the 2017 update to the OECD Model Tax Convention. In the draft, the OECD took notice of the comments INREV and others made. Several relevant changes now appear in the real estate example. 

Response filed to OECD BEPS Action 6 Discussion Paper

On 1 February, INREV filed a response to the OECD’s Discussion Paper on BEPS Action 6 related to tax treaty abuse and non-CIVs. Although the paper’s example on real estate was highly favourable for non-listed funds and reflected earlier INREV comments, the response prepared by the Tax Committee proposed some minor improvements that would improve clarity.

OECD delivers welcome news in BEPS Action 6 discussion draft

On 6 January, the OECD issued a discussion draft on Non-CIVs that includes a realistic example of a Real Estate non-CIV (example 3). Based on the facts and circumstances of the example, the OECD concluded that it would be unreasonable to deny treaty benefits to the holding company serving as the corporate investment platform of the non-CIV. In their example, the working party uses similar considerations to justify the use of the holding company as INREV did in its response to the non-CIV report.

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INREV comments on OECD’s Public Discussion Draft on Treaty Entitlement of Non-CIV Funds

On 22 April INREV filed comments in response to an OECD consultation impacting real estate vehicles. We argued that real estate vehicles should be entitled to protection of double tax treaties as they are not used for treaty shopping or tax deferral.

 

INREV recommends changes to OECD Action 6 treaty abuse draft

In a response filed on Tuesday 16 June to the OECD’s revised discussion draft on BEPS Action 6: prevent treaty abuse, INREV urges inclusion of real estate investment vehicles.

The response, developed with input from the Tax Committee, recommends that real estate vehicles be entitled to double tax treaty protection similar to active business enterprises.

 

INREV responds to OECD request on BEPS

Last week, INREV filed a response to the OECD request for comments on BEPS Action 6, which comments on their proposals to prevent double-tax treaty abuse and offers suggestions for ensuring that non-listed real estate investment vehicles continue to enjoy the protection of tax treaties.

 

Industry joins to fight OECD tax abuse proposal

On 23 May, INREV, joined by ten real estate industry associations, filed comments with the OECD on its tax abuse proposal.

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Response to OECD Tax Abuse proposal filed

Last week INREV filed a response to an OECD proposal on tax treaty abuse (BEPS – Base Erosion and Profit Shifting). If adopted the proposal could impact non-listed real estate funds being able to take advantage of the benefits of double taxation treaties.

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