Developing a Multilateral Instrument to Modify Bilateral Tax Treaties PDF Download
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Author: OCDE,
Publisher: OCDE
ISBN: 9789264241671
Category : Double taxation
Languages : en
Pages : 56
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Book Description
Drawing on the expertise of public international law and tax experts, this report explores the technical feasibility to develop a multilateral instrument to modify tax treaties so as to efficiently implement the tax treaty-related BEPS measures. The report concludes that such an instrument is desirable and feasible and that negotiations for the multilateral instrument should be convened quickly. Based on this analysis, a mandate has been developed for an ad-hoc group, open to the participation of all countries on an equal footing, to develop the multilateral instrument and open it for signature in 2016.
Author: OCDE,
Publisher: OCDE
ISBN: 9789264241671
Category : Double taxation
Languages : en
Pages : 56
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Book Description
Drawing on the expertise of public international law and tax experts, this report explores the technical feasibility to develop a multilateral instrument to modify tax treaties so as to efficiently implement the tax treaty-related BEPS measures. The report concludes that such an instrument is desirable and feasible and that negotiations for the multilateral instrument should be convened quickly. Based on this analysis, a mandate has been developed for an ad-hoc group, open to the participation of all countries on an equal footing, to develop the multilateral instrument and open it for signature in 2016.
Author: OECD
Publisher: OECD Publishing
ISBN: 926424168X
Category :
Languages : en
Pages : 58
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Book Description
Addressing base erosion and profit shifting (BEPS) is a key priority of governments. In 2013, OECD and G20 countries, working together on an equal footing, adopted a 15-point Action Plan to address BEPS. This publication is the final report for Action 15.
Author:
Publisher:
ISBN:
Category :
Languages : es
Pages : 54
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Book Description
Author: Oecd
Publisher: OCDE
ISBN: 9789264219243
Category : Business & Economics
Languages : en
Pages : 63
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Book Description
This report identifies the issues arising from the development of a multilateral instrument that modifies bilateral tax treaties. Without a mechanism for swift implementation, changes to model tax conventions only widen the gap between the content of these models and the content of actual tax treaties. Developing such a mechanism is necessary not only to tackle base erosion and profit shifting, but also to ensure the sustainability of the consensual framework to eliminate double taxation. This is an innovative approach with no exact precedent in the tax world, but precedents for modifying bilateral treaties with a multilateral instrument exist in various other areas of public international law. Drawing on the knowledge of experts in public international law and taxation, the Report concludes that a multilateral instrument is desirable and feasible, and that negotiations for such an instrument should be convened quickly.
Author:
Publisher:
ISBN:
Category :
Languages : en
Pages : 86
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Book Description
The Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (the Convention) is one of the outcomes of the OECD/G20 Project to tackle base erosion and profit shifting (the BEPS Project) i.e. tax planning strategies that exploit gaps and mismatches in tax rules to artificially shift profits to low or no-tax locations where there is little or no economic activity, resulting in little or no overall corporate tax being paid. The BEPS Action Plan was developed by the OECD Committee on Fiscal Affairs (CFA) and endorsed by the G20 Leaders in September 2013. It identified 15 actions to address base erosion and profit shifting (BEPS) in a comprehensive manner, and set out deadlines to implement those actions. Action 15 of the BEPS Action Plan provided for an analysis of the possible development of a multilateral instrument to implement tax treaty related BEPS measures "to enable jurisdictions that wish to do so to implement measures developed in the course of the work on BEPS and amend bilateral tax treaties". The Action 15 Report, "Developing a Multilateral Instrument to Modify Bilateral Tax Treaties", concluded that a multilateral instrument, providing an innovative approach to enable countries to swiftly modify their bilateral tax treaties to implement measures developed in the course of the work on BEPS, is desirable and feasible, and that negotiations for such an instrument should be convened quickly.
Author: Michael Lang
Publisher: Kluwer Law International B.V.
ISBN: 9041189165
Category : Law
Languages : en
Pages : 296
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Book Description
The Multilateral Instrument (MLI) proposed in OECD BEPS Action 15 will lead to the modification of numerous tax treaties. As tax treaties can have different wording, terminology and structure, a great challenge is to find a proper way to accomplish their modification without distorting the underlying framework or triggering undesirable effects. This book analyses the MLI, which was signed by over seventy jurisdictions on 7 June 2017. The topics covered include: • the procedural mechanisms on how the new measures to prevent base erosion and profit shifting (BEPS) will interact with and complement existing tax treaties; • the scope of the MLI in order to ascertain which tax treaties and taxes are covered; • the interpretation of terms used in the MLI and the relationship between the languages used in the MLI and in the particular tax treaties; • the implementation of the minimum standard through the MLI, as well as how states can exercise various options offered by the MLI and reserve the right not to apply certain provisions of the MLI; • the legal consequences of the exercise of options and reservations for the other states; • the notification procedure through which states declare their choices; and • the possibilities and procedure for withdrawal from the obligations entered into upon signing the MLI. Finally, the book discusses whether the mechanism of the MLI can serve as a role model for future changes to the OECD Model Convention. The book incorporates the analyses of leading scholars and practitioners dealing with international tax matters. Critical insights are offered for academics, practitioners, tax officials and judges who deal with or are interested in the field of international taxation.
Author: OECD
Publisher: OECD Publishing
ISBN: 9264237879
Category :
Languages : zh-CN
Pages : 51
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Book Description
Author: J. Malherbe
Publisher:
ISBN:
Category :
Languages : en
Pages :
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Book Description
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.
Author: OECD
Publisher: OECD Publishing
ISBN: 9264241132
Category :
Languages : en
Pages : 458
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Book Description
Addressing base erosion and profit shifting (BEPS) is a key priority of governments. In 2013, OECD and G20 countries, working together on an equal footing, adopted a 15-point Action Plan to address BEPS. This publication is the final report for Action 2.
Author: Nathalie Bravo
Publisher:
ISBN: 9789087225919
Category : Double taxation
Languages : en
Pages : 339
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Book Description
A precise and in-depth analysis of the Multilateral Instrument and of how it impacts the tax treaty network by implementing the treaty-related BEPS measures.
