EFAMA is grateful for the opportunity to comment on the new OECD Public Discussion Draft on BEPS Action 6 and the treaty entitlement of non-CIV funds Discussion Draft on non-CIV examples. In addition EFAMA would like to make positive use of this opportunity and comment as well on the general situation of CIVs as well as of Non-CIVs against the background of the BEPS Action 6 implementation.

The paper at hand sets the views and concerns of the European investment management industry with regards to the impact of OECD BEPS Action 6 on this industry. Below we made some general comments before responding to the OECD Public Discussion Draft.