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The BEPS multilateral instrument: anti-abuse provisions

Heather Self (Pinsent Masons) looks at the possible implications of the way this brings into effect a key recommendation from the BEPS Action 6 report.

The publication of the final version of the OECD Multilateral Instrument (MLI) in November 2016 was a huge achievement and great credit is due to Mike Williams of HM Treasury who chaired the working party and brought around 100 countries to a consensus position. Inevitably compromises had to be made and one key point to note is that the MLI allows for a range of different options on implementation. It will be interesting to see whether all the faces of this multidimensional Rubik’s hypercube align by the time of the proposed signing ceremony in June 2017.
 
The MLI is just one part of the BEPS implementation process. It deals with the minimum standards required...

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