The OECD has released a follow-up discussion draft on the interaction between the treaty provisions of the BEPS 6 report on double tax treaty access and the entitlement of non-CIV funds (broadly, non-UCITS type funds). Other than general comments around the simplified and detailed limitation on benefit (LOB) rule, the discussion paper includes three examples of fund structures that would determine the application of the principal purpose test (PPT) . The outcome of the consultation should inform the next governmental working party meeting (WP1) in February and be taken into account in the revision of the commentaries to the OECD Model Tax Convention on Income and on Capital (the OECD Model), which is provisionally scheduled for mid-2017. Closing date for responses is 3 February 2017, and AIMA will be responding to the discussion paper. For further information, please contact Paul Hale or Enrique Clemente.