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Preventing tax treaty abuseModel Tax Convention on Income and on Capital 4 (OECDModel Convention) and changes to domestic tax rules;‣ ¾ Clarifying, possibly within the text of the OECD ModelConvention, the Commentary or elsewhere, that tax treatiesare not intended to generate double non-taxation. It is presumablythis theme which would be coordinated with the work onhybrids; 5 and‣ ¾ Developing recommendations about the considerations whichshould influence a country in deciding whether to enter into atax treaty with another country.1.2 Public Discussion Draft (March 2014)In March 2014, the OECD issued a second document, Public DiscussionDraft, BEPS Action 6: Preventing the Granting of Treaty Benefits inInappropriate Circumstances 6 (OECD Public Discussion Draft onAction 6), elaborating the Action in more detail. 7 It made recommenda-4OECD, Model Tax Convention on Income and on Capital (Paris:OECD, 2014).5A separate discussion paper was issued by the OECD in March 2014dealing with amendments to the OECD Model Convention and Commentaryto address the problem of hybrid entities and instruments. See OECD,Public Discussion Draft, BEPS Action 2: Neutralise the Effects of Hybrid MismatchArrangements (Treaty Issues) (Paris: OECD, 2014), available at http://www.oecd.org/ctp/treaties/hybrid-mismatch-arrangements-discussiondraft-treaty-issues-march-2014.pdf.6OECD, Public Discussion Draft, BEPS Action 6: Preventing the Grantingof Treaty Benefits in Inappropriate Circumstances (Paris: OECD, 2014),available at http://www.oecd.org/ctp/treaties/treaty-abuse-discussion-draftmarch-2014.pdf.7The OECD Action Plan on BEPS in 2013 had identified as the outputsfrom this Action both proposals for changes to the text of the OECD ModelConvention and “recommendations regarding the design of domestic rules.”See OECD, Action Plan on Base Erosion and Profit Shifting, supra note 3, at31. The March 2014 document focuses principally on proposals for changes tothe text of the OECD Model Convention and the Commentary thereon. It isnot clear whether future OECD work will propose drafts of domestic legislationdesigned to implement or buttress the treaty proposals.277