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The Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS—Some Thoughts on Complexity and Uncertainty Cover

The Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS—Some Thoughts on Complexity and Uncertainty

Nordic Tax Journal
Volume 2018 (2018): Issue 1 (January 2018)
By:   
Open Access
|Apr 2018
Figures & tables

Figures & Tables

Figure 1

Impact of MLI articles that do not reflect minimum standards

Table 1

Reservations against articles in their entirety made by signatory states representing the world’s 20 largest economies

State/Article34589301011121314
ChinaR----R-RRR
Japan---R--R--R
GermanyRR----RR-R
United Kingdom---RRR-R-R
FranceRRR--RR---
IndiaR-R-------
ItalyRR-31R-RRR-R
CanadaRRRRRRRRRR
South KoreaRRRRRRRRRR
Russia--R-------
Spain-R----R--R
Australia-----R-R--
Mexico---------R
IndonesiaR-R--R----
Turkey-RRR-RR--R
Netherlands------R---
SwitzerlandRR-RRRRRRR
Number of reservations9877410108411

30 With regard to Art. 9, a reservation against Art. 9(1) without opting in to Art. 9(4) has been deemed a reservation against the article in its entirety, as it would mean that the article is not given any effect.

31 Italy has not chosen to apply any of the options under Art. 5 but accepts that the other contracting state changes its method for elimination of double taxation and, therefore, does not make a reservation.

DOI: https://doi.org/10.1515/ntaxj-2018-0001 | Journal eISSN: 2246-1809
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Language: English
Page range: 31 - 48
Submitted on: Oct 25, 2017
Accepted on: Jan 29, 2018
Published on: Apr 19, 2018
Published by: DJØF Publishing, Nordic Tax Research Council
In partnership with: Paradigm Publishing Services
Keywords:
Tax treaty,
Multilateral instrument,
MLI,
BEPS,
base erosion,
rule complexity,
legal uncertainty,
Multilateral Convention to Implement Tax Treaty Related Measures,
PPT,
principal purpose test,
treaty antiabuse rules
Related subjects:
Business and economics,
Political economics,
Public finance and fiscal theory,
Business management,
Business law,
Law,
History, philosophy and sociology of law,
Public law,
Tax and accounting law

© 2018 David Kleist, published by DJØF Publishing, Nordic Tax Research Council
This work is licensed under the Creative Commons Attribution-NonCommercial-NoDerivatives 4.0 License.

Volume 2018 (2018): Issue 1 (January 2018)
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