OECD Multilateral Instrument: The New Era in International Tax Law
OECD Multilateral Instrument: The New Era in International Tax Law
Author(s): Bartosz Bacia, Patryk Emanuel TOPOROWSKISubject(s): Law, Constitution, Jurisprudence, Law on Economics
Published by: ASERS Publishing
Keywords: MLI; withholding tax; hybrid mismatch; OECD; BEPS; double taxation;
Summary/Abstract: The Multilateral Instrument to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) is one action by the OECD to address tax-base erosion and profit shifting (BEPS), i.e., double non-taxation or strategies consisting of artificially shifting profits to low-tax locations where there is no substantial economic activity and at the same time, very little corporate tax being paid. MLI aims to modify bilateral double-taxation agreements. It is an international agreement that modifies, in an umbrella manner, the relevant provisions of bilateral double-taxation agreements. Standard clauses contained in the MLI should replace, modify or supplement the relevant clauses in bilateral agreements. MLI marks a new opening in international tax law, offering for the first time the ability to harmonize the rules governing cross-border taxation.
Journal: Journal of Advanced Research in Law and Economics (JARLE)
- Issue Year: IX/2018
- Issue No: 32
- Page Range: 386-395
- Page Count: 9
- Language: English
- Content File-PDF