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
According to the BEPS Action 15 Final report, a Multilateral Instrument (MLI) was opened for signature in 2017 through which jurisdictions could amend their bilateral conventions for the avoidance of double taxation to insert new clauses. Some were part of a minimum standard: a preamble and a principle purpose test (PPT) designed to avoid non-taxation and treaty abuse; a mutual agreement procedure (MAP). Others are subject to innovations, such as artificial avoidance of a PE status or options, such as limitation on benefits or arbitration. This article comments on those clauses and their status
Citation source
In: Revista de finanças públicas e direito fiscal. - Coimbra. - Vol. 11 (2018), no. 1/2 ; p. 13-49
http://library.link/vocab/creatorName
Malherbe, J
Geographic coverage
International
Language note
English
http://library.link/vocab/subjectName
  • MLI
  • tax treaty
  • BEPS Project (OECD)
  • PE
  • principal purpose test
  • treaty abuse
  • double non-taxation
  • MAP
  • 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 ...