The Limitation on Benefits Article in the OECD Model: Closing Abusive (Undesired) Conduit Gateways

The author, in this article, considers Action 6 of the OECD Base Erosion and Profit Shifting initiative regarding the inclusion of a limitation on benefits article in the OECD Model and the implications of such a development, especially in relation to tax planning and the use of conduit structures.