The Resource Action 2 and the Multilateral Instrument : is the reservation power putting coordination at stake?

Action 2 and the Multilateral Instrument : is the reservation power putting coordination at stake?

Label
Action 2 and the Multilateral Instrument : is the reservation power putting coordination at stake?
Title
Action 2 and the Multilateral Instrument : is the reservation power putting coordination at stake?
Creator
Subject
Language
eng
Summary
This article analyses the effectiveness of the Multilateral Instrument (MLI) provisions on hybrids taking into account both the coordination requirement of base erosion and profit shifting (BEPS) Action 2 and the reservations power on the MLI. For this purpose, the article explains the coordination requirement in light of BEPS Action 2 recommendations and the need to modify tax treaties. Besides including the description of the MLI provisions on hybrids, in its third part, the article tests such coordination. This section doesn't only show that an important part of the MLI signing parties adopted reservations to said articles, but also criticizes the lack of discussion regarding the allocation of the taxing rights
Citation source
In: Intertax. - Alphen aan den Rijn. - Vol. 46 (2018), no. 2 ; p. 104-114
Language note
English
Label
Action 2 and the Multilateral Instrument : is the reservation power putting coordination at stake?
Instantiates
Publication
Label
Action 2 and the Multilateral Instrument : is the reservation power putting coordination at stake?
Publication

Library Locations

    • IBFD Library AmsterdamBorrow it
      Rietlandpark 301, Amsterdam, 1019 DW, NL
      52.37366609999999 4.9336932
Processing Feedback ...