The Proposed OECD Multilateral Instrument Amending Tax Treaties.

Autor: Austry, Stéphane, Jones, John Avery, Baker, Philip, Blessing, Peter, Danon, Robert, Goradia, Shefali, Inoue, Koichi, Lüdicke, Jürgen, Maisto, Guglielmo, Toshio Miyatake, Nikolakakis, Angelo, van Raad, Kees, Vann, Richard, Wiman, Bertil
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Zdroj: British Tax Review; 2016, Issue 4, p454-465, 12p
Abstrakt: This article expands on the authors' response to the OECD discussion draft on a multilateral instrument (MLI) to amend bilateral tax treaties in accordance with BEPS proposals. It concentrates on whether it would be better for the MLI to amend existing bilateral treaties and then fall away, or to continue in being as a multilateral treaty to be read in conjunction with the bilateral treaties that it amends as a move towards a multilateral approach to tax treaties. The two alternatives are considered in the light of the status of explanatory statements about the amendments, the issue of the official languages of the MLI and of the bilateral treaties that it amends, and the domestic implementation procedures for the MLI. [ABSTRACT FROM AUTHOR]
Databáze: Supplemental Index