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OECD delivered on October 5th 2015 the BEPS final package consisting of 15 actions intending to address the issues of base erosion and profit shifting. The aim of Action 6 is to prevent treaty abuse, in particular treaty shopping. To achieve this goal, a specific anti- abuse rule, a Limitation- on- Benefit (LOB) rule, will be included in the OECD Model. The LOB rule contains objective tests that t
