Is BEPS Action 6 “Preventing Treaty abuse” compatible with the EU Law concept of abuse?
In September 2015, the OECD released the final report on BEPS action 6. The main purpose of the action 6 is the prevention of "granting treaty benefits in inappropriate circumstances". Regarding the prevention of treaty abuse the OECD presented three main recommendations. These actions are only proposals and therefore they constitute soft law. However with their implementation in the tax