BEPS: OECD Multilateral Convention – 8 December 2016
On 24 November 2016, the OECD released the widely-anticipated text of the Multilateral Convention to Implement Tax Treaty-Related Measures to prevent Base Erosion and Profit Shifting (BEPS).
The Multilateral Convention to Implement Tax Treaty-Related Measures to prevent BEPS (the Convention) is a result of the work under BEPS Action 15. The Convention is designed to swiftly implement the tax treaty-related measures arising from the G20/OECD BEPS project. It includes articles on hybrid mismatches (Action 2), treaty abuse (Action 6), permanent establishments (Action 7) and improving dispute resolution (Action 14). The Convention will be open for signature from 31 December 2016, and a signing ceremony in Paris is planned for 5 June 2017. Australia actively participated in the negotiation of the Convention and a discussion paper is expected to be released by Treasury shortly.