Impact of the OECD Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting on the Taxation of Fiscally Transparent Entities Under the Australia - UK Double Tax Agreement PDF Download

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Impact of the OECD Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting on the Taxation of Fiscally Transparent Entities Under the Australia - UK Double Tax Agreement

Impact of the OECD Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting on the Taxation of Fiscally Transparent Entities Under the Australia - UK Double Tax Agreement PDF Author: J.G. Azzi
Publisher:
ISBN:
Category :
Languages : en
Pages :

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Book Description
This article examines the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) in relation to fiscally transparent entities; specifically limited partnerships which are taxed as flow-through entities in one jurisdiction but as companies in another. Focusing on the adoption positions of Australia and the UK, this article analyses how the MLI impacts the treatment of fiscally transparent entities under the Australia-UK Double Tax Agreement. To add practical perspective, the article further examines the Australian decision in Commissioner of Taxation v Resource Capital Fund III LP, which raises a number of important issues embodied in the MLI concerning the application of principles in the 1999 OECD Partnership Report and the mutual agreement procedure (MAP) for resolving treaty-related disputes in Article 25 of the OECD Model Tax Convention. Whilst acknowledging the immense achievement of the OECD and the ad hoc Group in securing international consensus in relation to the multifarious MLI, nevertheless the article concludes the MLI is unlikely to achieve its primary objective to improve predictability and certainty for governments and businesses notwithstanding the option of 'mandatory binding arbitration'.

Impact of the OECD Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting on the Taxation of Fiscally Transparent Entities Under the Australia - UK Double Tax Agreement

Impact of the OECD Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting on the Taxation of Fiscally Transparent Entities Under the Australia - UK Double Tax Agreement PDF Author: J.G. Azzi
Publisher:
ISBN:
Category :
Languages : en
Pages :

Get Book Here

Book Description
This article examines the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) in relation to fiscally transparent entities; specifically limited partnerships which are taxed as flow-through entities in one jurisdiction but as companies in another. Focusing on the adoption positions of Australia and the UK, this article analyses how the MLI impacts the treatment of fiscally transparent entities under the Australia-UK Double Tax Agreement. To add practical perspective, the article further examines the Australian decision in Commissioner of Taxation v Resource Capital Fund III LP, which raises a number of important issues embodied in the MLI concerning the application of principles in the 1999 OECD Partnership Report and the mutual agreement procedure (MAP) for resolving treaty-related disputes in Article 25 of the OECD Model Tax Convention. Whilst acknowledging the immense achievement of the OECD and the ad hoc Group in securing international consensus in relation to the multifarious MLI, nevertheless the article concludes the MLI is unlikely to achieve its primary objective to improve predictability and certainty for governments and businesses notwithstanding the option of 'mandatory binding arbitration'.

OECD/G20 Base Erosion and Profit Shifting Project Preventing the Granting of Treaty Benefits in Inappropriate Circumstances

OECD/G20 Base Erosion and Profit Shifting Project Preventing the Granting of Treaty Benefits in Inappropriate Circumstances PDF Author: OECD
Publisher: OECD Publishing
ISBN: 9264219129
Category :
Languages : en
Pages : 112

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Book Description
This report from the OECD/G20 Base Erosion and Profit Shifting project examines the issue of preventing the granting of treaty benefits in inappropriate circumstances. It includes proposed changes to the OECD Model Tax convention and summarises progress to date.

OECD/G20 Base Erosion and Profit Shifting Project Developing a Multilateral Instrument to Modify Bilateral Tax Treaties

OECD/G20 Base Erosion and Profit Shifting Project Developing a Multilateral Instrument to Modify Bilateral Tax Treaties PDF Author: OECD
Publisher: OECD Publishing
ISBN: 9264219250
Category :
Languages : en
Pages : 67

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Book Description
Produced by the OECD/G20 Base Erosion and Profit Shifting Project, this report identifies the issues arising from the development of a multilateral instrument that modifies bilateral tax treaties.

OECD/G20 Base Erosion and Profit Shifting Project Developing a Multilateral Instrument to Modify Bilateral Tax Treaties, Action 15 - 2015 Final Report

OECD/G20 Base Erosion and Profit Shifting Project Developing a Multilateral Instrument to Modify Bilateral Tax Treaties, Action 15 - 2015 Final Report PDF 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.

Explanatory Statement to the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting

Explanatory Statement to the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting PDF 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.

Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting

Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting PDF Author:
Publisher:
ISBN:
Category :
Languages : en
Pages : 48

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Book Description
More than 100 jurisdictions have concluded negotiations on a multilateral instrument (MLI) that will swiftly implement a series of tax treaty measures to update international tax rules and lessen the opportunity for tax avoidance by multinational enterprises. The new instrument will transpose results from the OECD/G20 Base Erosion and Profit Shifting (BEPS) Project into more than 2000 tax treaties worldwide. A signing ceremony will be held in June 2017 in Paris.

OECD/G20 Base Erosion and Profit Shifting Project Prevention of Tax Treaty Abuse – Fifth Peer Review Report on Treaty Shopping Inclusive Framework on BEPS: Action 6

OECD/G20 Base Erosion and Profit Shifting Project Prevention of Tax Treaty Abuse – Fifth Peer Review Report on Treaty Shopping Inclusive Framework on BEPS: Action 6 PDF Author: OECD
Publisher: OECD Publishing
ISBN: 9264989722
Category :
Languages : en
Pages : 319

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Book Description
Under the BEPS Action 6 minimum standard on treaty shopping, members of the OECD/G20 Inclusive Framework on BEPS have committed to strengthen their tax treaties by implementing anti-abuse measures. This report reflects the outcome of the fifth peer review of the implementation of the BEPS Action 6 minimum standard on treaty shopping.

OECD/G20 Base Erosion and Profit Shifting Project Prevention of Tax Treaty Abuse – Sixth Peer Review Report on Treaty Shopping Inclusive Framework on BEPS: Action 6

OECD/G20 Base Erosion and Profit Shifting Project Prevention of Tax Treaty Abuse – Sixth Peer Review Report on Treaty Shopping Inclusive Framework on BEPS: Action 6 PDF Author: OECD
Publisher: OECD Publishing
ISBN: 9264760911
Category :
Languages : en
Pages : 325

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Book Description
Under the BEPS Action 6 minimum standard on treaty shopping, members of the OECD/G20 Inclusive Framework on BEPS have committed to strengthen their tax treaties by implementing anti-abuse measures. This report reflects the outcome of the sixth peer review of the implementation of the BEPS Action 6 minimum standard on treaty shopping.

OECD/G20 Base Erosion and Profit Shifting Project Neutralising the Effects of Hybrid Mismatch Arrangements

OECD/G20 Base Erosion and Profit Shifting Project Neutralising the Effects of Hybrid Mismatch Arrangements PDF Author: OECD
Publisher: OECD Publishing
ISBN: 9264218815
Category :
Languages : en
Pages : 103

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Book Description
This report, produced by the OECD/G20 Project on Base Erosion and Profit Shifting sets out recommendations for domestic rules to neutralise the effect of hybrid mismatch arrangements and includes changes to the OECD Model Tax Convention to address such arrangements.

OECD/G20 Base Erosion and Profit Shifting Project Prevention of Tax Treaty Abuse – Third Peer Review Report on Treaty Shopping Inclusive Framework on BEPS: Action 6

OECD/G20 Base Erosion and Profit Shifting Project Prevention of Tax Treaty Abuse – Third Peer Review Report on Treaty Shopping Inclusive Framework on BEPS: Action 6 PDF Author: OECD
Publisher: OECD Publishing
ISBN: 9264950982
Category :
Languages : en
Pages : 302

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Book Description
The BEPS Action 6 minimum standard on preventing the granting of treaty benefits in inappropriate circumstances, is one of the four BEPS minimum standards that all members of the OECD/G20 Inclusive Framework on BEPS (Inclusive Framework) have committed to implement. This report reflects the outcome of the third peer review of the implementation of the Action 6 minimum standard on treaty shopping as approved by the Inclusive Framework.