Insights

68 jurisdictions sign the OECD Multilateral Instrument

The Convention is designed to implement swiftly the tax treaty-related measures arising from the G20/OECD Base Erosion and Profit Shifting (‘BEPS’) Project.

‘Minimum standard’ changes to the functioning of existing double tax conventions in the areas of treaty abuse, mutual agreement procedures and treaty preambles will be implemented through the Convention and, depending on the reservations and notifications made by each party, optional changes to modify tax treaties in respect of permanent establishments (taxable presence), transparent entities, residency tie-breakers, double tax relief, minimum shareholding periods, capital gains derived from immovable property and a jurisdiction’s right to tax its own residents will also be facilitated. 

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