Ashley Greenbank and Catherine Hill (Macfarlanes) set out the timeline that will amend many of the UK’s double taxation treaties.
What is the MLI?
The multilateral instrument (MLI) was designed to implement those parts of the OECD/G20 BEPS recommendations that required (or recommended) changes to the double taxation treaties of participating states.
Changes to treaty provisions were included as part of the recommendations in each of: Action 2 (hybrid instruments); Action 6 (treaty abuse); Action 7 (permanent establishment status); and Action 14 (effective dispute resolution).
The aim of the MLI is to provide an efficient mechanism for making the numerous changes that could need to be made to the network of bilateral treaties between participating states without requiring the separate negotiation and ratification of the amendments to each of those treaties. It is a complex document and no doubt in an attempt to ensure that as many...
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Ashley Greenbank and Catherine Hill (Macfarlanes) set out the timeline that will amend many of the UK’s double taxation treaties.
What is the MLI?
The multilateral instrument (MLI) was designed to implement those parts of the OECD/G20 BEPS recommendations that required (or recommended) changes to the double taxation treaties of participating states.
Changes to treaty provisions were included as part of the recommendations in each of: Action 2 (hybrid instruments); Action 6 (treaty abuse); Action 7 (permanent establishment status); and Action 14 (effective dispute resolution).
The aim of the MLI is to provide an efficient mechanism for making the numerous changes that could need to be made to the network of bilateral treaties between participating states without requiring the separate negotiation and ratification of the amendments to each of those treaties. It is a complex document and no doubt in an attempt to ensure that as many...
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:
