15 January 2016

OECD BEPS final reports have implications for sovereign wealth and pension funds

The Organization for Economic Co-Operation and Development (OECD) released the final reports on the 15 Action points identified in its Action Plan on Base Erosion and Profit Shifting (BEPS) on October 5, 2015. It is anticipated that the measures laid out in the Action items will be implemented via changes in domestic law and practices and changes in treaty provisions (including through the multilateral instrument being developed as a mechanism to amend existing bilateral treaties which is currently in progress and expected to be ready for signature at the end of 2016). It is acknowledged in the reports that further work is required in respect of the policy considerations related to non-Collective Investment Vehicles (non-CIVs) including sovereign wealth and pension funds (SW&PFs). However, investors are seeking to remove uncertainty as to how the proposed Action items affect them, especially as these Action items begin to be implemented in various countries.

A Tax Alert prepared by Ernst & Young Canada, and attached below, provides additional details.

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Document ID: 2016-0107