A New Tax Treaty for a New World : the Multilateral Convention to Implement Tax Treaty-related Measures to Prevent Base Erosion and Profit Shifting

Download or read book A New Tax Treaty for a New World : the Multilateral Convention to Implement Tax Treaty-related Measures to Prevent Base Erosion and Profit Shifting written by J. Malherbe and published by . This book was released on 2018 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: 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.