The Resource A new tax treaty for a new world : the Multilateral Convention to implement tax treaty-related measures to prevent base erosion and profit shifting

A new tax treaty for a new world : the Multilateral Convention to implement tax treaty-related measures to prevent base erosion and profit shifting

Label
A new tax treaty for a new world : the Multilateral Convention to implement tax treaty-related measures to prevent base erosion and profit shifting
Title
A new tax treaty for a new world : the Multilateral Convention to implement tax treaty-related measures to prevent base erosion and profit shifting
Creator
Subject
Language
eng
Summary
In October 2015, the OECD released the final reports on the 15 action items of the BEPS Action Plan. It contained recommendations concerning different categories, with such recommendations widing from minimum standards (which all members of the Inclusive Framework on BEPS agree to implement), reinforced international standards and common approaches. The text of the Multilateral Instrument (MLI) and its Explanatory Statement (Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting) has been developed and agreed - under a mandate given by G20 Finance Ministers and Central Bank Governors at their February 2015 meeting - on 24 November 2016 by approximately 100 jurisdictions including OECD member countries, G20 countries and other developed and developing countries. However, it is open for signature to any interested jurisdictions. The Author deals with the actual solutions for governments introduced by the MLI to fill the gaps in existing international tax rules by switching outcomes from the OECD/G20 BEPS Project into bilateral tax treaties. Indeed, the MLI changes the application of thousands of bilateral tax treaties concluded to cancel double taxation. It also applies agreed minimum standards to counter treaty abuse and to improve dispute resolution procedures while providing adaptability to give room for certain tax treaty policies. In other words, MLI states a series of tax treaty measures to update international tax rules and lower the area for tax avoidance by multinational corporations. The expectation that over 1,000 tax treaties worldwide will be modified because of the current positions of the countries that have now signed the MLI represents an unprecedented step in international taxation as well as in the international relations, a significant milestone in the application of the BEPS measures
Citation source
In: Rivista di diritto tributario internazionale = International tax law review. - Roma. - (2018), no. 2 ; p. 9-41
http://library.link/vocab/creatorName
Malherbe, J
Geographic coverage
International
Language note
English
http://library.link/vocab/subjectName
  • BEPS Project (OECD)
  • MLI
  • tax treaty
  • PE
  • MAP
  • principal purpose test
  • treaty abuse
  • double non-taxation
  • LoB
  • arbitration
Label
A new tax treaty for a new world : the Multilateral Convention to implement tax treaty-related measures to prevent base erosion and profit shifting
Instantiates
Publication
Label
A new tax treaty for a new world : the Multilateral Convention to implement tax treaty-related measures to prevent base erosion and profit shifting
Publication

Library Locations

    • IBFD Library AmsterdamBorrow it
      Rietlandpark 301, Amsterdam, 1019 DW, NL
      52.3736660 4.9336932
Processing Feedback ...