PRELIMINARY AGENDA

TH
OECD 20 ANNUAL TAX TREATY MEETING

Global Forum on Tax Treaties

Paris, 3-4 November 2015

OECD Conference Centre

2 rue André Pascal, Paris 16th, France

TUESDAY, 3 NOVEMBER 2015

09.00 – 09.30 REGISTRATION

09.30 – 9.55 OPENING OF THE MEETING

Welcoming address: Pascal SAINT-AMANS, Director, OECD Centre for Tax Policy and
Administration
9.55 – 11.15 SESSION 1: BEPS PROJECT: INTRODUCTION TO THE FINAL REPORTS PART I
The outcomes of the work on the Action Plan on Base Erosion and Profit Shifting (the BEPS Action Plan) will be delivered
to the G20 in early October. This first session start with an overview of the key themes in the 2015 deliverables. The
session will explain how the deliverables will help to align taxation with value creation, to be further illustrated by a case
study explaining how the holistic approach of the BEPS projects counters the use of cash boxes.

11.15 – 11.45 Coffee Break

11.45 – 13.00 SESSION 2: BEPS PROJECT: INTRODUCTION TO THE FINAL REPORTS PART II
This session will be a follow up on Session 1 and will emphasise on the outcomes of Action 1 and 2. The relevance for tax
treaties of the outcomes of these Action will be examined. Delegates are invited to share their view on the impact of these
Actions on the Model Tax Convention.

13.00 – 14.30 Lunch Break

14.30 – 15.45 SESSION 3: ACTION 6 – PREVENTING TREATY ABUSE: THE FINAL REPORT
This session will examine the results of the work on Action 6 - Preventing treaty abuse. The first part of the session
introduces the three elements of the final report on this Action – (A) treaty provisions and/or domestic rules to prevent the
granting of treaty benefits; (B) a clarification that tax treaties are not intended to be used to generate double non-taxation;
and (C) tax policy considerations that, in general, countries should consider before deciding to enter into a tax treaty with
another country. Then, the minimum standard presented in Part A of the report will be introduced, and delegates will be
invited to discuss the impact of the work on Action 6 on the basis of case studies.

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15.45 – 16.15 Coffee Break

16.15 – 17.30 Session 4: ACTION 6 (CONTINUED)

Continuation of Session 3.

17.45 COCKTAIL
Participants are invited to attend a cocktail.

WEDNESDAY, 4 NOVEMBER 2015

09.30 – 10.45 SESSION 5: ACTION 7 – PREVENT THE ARTIFICIAL AVOIDANCE OF PE STATUS

This session will focus on the outcomes of the work on Action 7 – Prevent the artificial avoidance of PE status.
Participants will have the opportunity to discuss the practical impact of the outcomes of that work on the basis of case
studies. The session will focus on the three main aspects of that work:

1) Artificial avoidance of PE status through commissionaire arrangements and similar strategies

2) Artificial avoidance of PE status through the specific exceptions in Art. 5(4)
3) Other strategies for the artificial avoidance of PE status.

The session will conclude with a discussion of the follow-up work planned in relation to PEs, in particular in relation to
the determination of profits to be attributed to the PEs that will result from the changes included in the Action 7 report.

10.45 – 11.15 Coffee Break

11.15 – 12.30 SESSION 6: ACTION 7 – PREVENT THE ARTIFICIAL AVOIDANCE OF PE STATUS (CONTINUED)
Continuation of Session 5.

12.30 – 14.00 Lunch Break

14.00 – 15.00 SESSION 7: ACTION 14 – MAKE DISPUTE RESOLUTION MECHANISMS MORE EFFECTIVE
This session will discuss the report on Action 14 (Make dispute resolution mechanisms more effective). The session will
cover the minimum standards that will improve MAPs, as well the supplementary commitment of a large group of
countries towards mandatory binding arbitration.

15.00 – 15.30 Coffee Break

15.30 – 16:15 SESSION 8: ACTION 15: DEVELOPING A MULTILATERAL INSTRUMENT

So far, 87 countries have joined the Ad hoc Group that will negotiate the multilateral instrument. This last session will link
the Annual Tax Treaty Meeting with the Inaugural Meeting of the ad hoc Group on the multilateral instrument, which will
take place on 5 and 6 November.

16.15 – 17:15 SESSION 9: A VIEW ON THE POST BEPS ENVIRONMENT AND CLOSING REMARKS
This session will cover the key challenges and opportunities related to the implementation of the different action items of
the BEPS Project. Delegates are cordially invited to discuss the continued participation of non-OECD countries in BEPS
and follow up projects.