Response to OECD Consultation on the Treaty Entitlement of Non-CIV Funds

25 April 2016

Irish Funds has responded to the OECD Consultation on the Treaty Entitlement of Non-CIV Funds. This consultation forms part of the BEPS Action 6 initiative on “Preventing the Granting of Treaty Benefits in Inappropriate Circumstances”. The consultation considers the tax treaty entitlement of investment funds that are not “collective investment vehicles (“CIVs”). Such investment funds, which would include AIFs that do not meet the definition of a CIV, have been termed “non-CIV funds”.

Irish Funds has responded to highlight the importance of granting appropriate treaty access to regulated collective investment schemes (AIFs as well as UCITS) and provides supporting commentary in that regard. The submission provides feedback on the various suggestions consulted upon and asks for the opportunity to further engage with the OECD on any emerging consensus on the course of action to be taken in relation to non-CIVs. The comments focus on investment funds in a cross-border context.

It is understood that a position on non-CIVs is intended to be presented to the G-20 for approval on 15-16 November 2016. Irish Funds will continue to engage in the ongoing dialogue on this subject.

Read the full Irish Funds response.

Previous Irish Funds responses to the OECD BEPS Action 6 related consultations are available on our tax page.