Patrick Marley

The OECD recently released a discussion draft entitled the “BEPS Action 6 Discussion Draft on non-CIV examples” to clarify when investors like private equity funds should be entitled to tax treaty benefits. In a PE Hub Canada feature article, Osler, Hoskin & Harcourt LLP Partners Patrick Marley and Matias Milet argue the document does little to dispel uncertainty about the application of rules governing transactions involving PE investors. This, they say, may adversely impact cross-border investment.