Jeremy Webster and Jamie Robson (Pinsent Masons) consider how the MLI amends existing DTTs, and examine whether the principal purpose test would apply in a given scenario.
The Organisation for Economic Cooperation and Development’s (OECD) project on base erosion and profit shifting (BEPS) is now much publicised. We are entering a new phase of the BEPS process where double tax treaties (DTTs) are to be amended in line with certain parts of the OECD’s BEPS Action Plan published in 2015. The instrument effecting these amendments is the Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting also known as the multilateral instrument (MLI).
The MLI as an instrument seeks to amend existing DTTs without requiring bilateral negotiations in respect of each and every DTT. Broadly the MLI covers the following areas:
hybrid mismatches;
treaty abuse;
...
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Jeremy Webster and Jamie Robson (Pinsent Masons) consider how the MLI amends existing DTTs, and examine whether the principal purpose test would apply in a given scenario.
The Organisation for Economic Cooperation and Development’s (OECD) project on base erosion and profit shifting (BEPS) is now much publicised. We are entering a new phase of the BEPS process where double tax treaties (DTTs) are to be amended in line with certain parts of the OECD’s BEPS Action Plan published in 2015. The instrument effecting these amendments is the Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting also known as the multilateral instrument (MLI).
The MLI as an instrument seeks to amend existing DTTs without requiring bilateral negotiations in respect of each and every DTT. Broadly the MLI covers the following areas:
hybrid mismatches;
treaty abuse;
...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
