The MLI and the share deal
The MLI is an instrument deployed by the OECD for amending a multitude of bilateral tax treaties in “one go”.
The share deal. In some markets it is the “benchmark” for transferring individual real estate assets. During a Hay Day in the real estate markets entire real estate portfolios tend to be transferred in the form of share deals. Could this practice be impacted by the OECD Multilateral Instrument (the “MLI”)? After all, under the MLI countries could change the allocation of taxing rights if shares in a “real estate company” are transferred. In this article we take a closer look at the relevant parts of the MLI and whether it could indeed impact share deals.
REflexions issue 6 - November 2017
REflexions is a bi-annual digest, dedicated to the real estate investment management professionals, which brings you the latest articles, news and market developments from Deloitte’s professionals and clients.