Many of the BEPS actions have resulted in agreed changes to the OECD Model Tax Convention. These changes must be implemented swiftly, efficiently and consistently to ensure that treaty-related BEPS issues can be addressed. The ordinary way for implementing such treaty changes would be for each country to renegotiate its existing bilateral tax treaties, which would take decades to complete given the size of the existing network of more than 3,000 tax treaties globally. The project therefore included a commitment to develop a multilateral instrument to sidestep this problem. Jesse Eggert and Evelyn Lio explain.
Unlock this content.
The content you are trying to view is exclusive to our subscribers.
Richard Gregg is no longer fit and proper to be a tax agent, said the TPB; in other news, MHA completed its acquisition of Baker Tilly South-East Europe
Recent Indian case law emphasises the importance of economic substance over mere legal form in evaluating tax implications, say authors from Khaitan & Co
As we move into an era of ‘substance over form’, determining the fundamental nature of a particular instrument is key when evaluating the tax implications of selling hybrid securities
After years of deafening silence, the UK tax authority is taking overdue action against corporates that fail to prevent the facilitation of tax evasion