Today, the OECD released a discussion draft on the prevention of treaty abuse.  The discussion draft contains follow-up work on Action 6 (“preventing the granting of treaty benefits in inappropriate circumstances”) of the Base Erosion and Profit Shifting (BEPS) Action Plan.  Specifically, it addresses the limitation on benefits provisions of the OECD model treaty as well as issues related to the treaty entitlement of collective investment vehicles (CIVs) and non-CIV funds.  The discussion draft also looks at issues related to the principal purpose test.