Developing a Multilateral Instrument to Modify Bilateral Tax Treaties [electronic resource] / Organisation for Economic Co-operation and Development

Format:

Book

Government document

Author/Creator:

Organisation for Economic Co-operation and Development.

Contributor:

Organisation for Economic Co-operation and Development, sponsoring body.

Series:

OECD/G20 Base Erosion and Profit Shifting Project, 23132612.

Language:

English

Subjects (All):

Corporations--Taxation--Law and legislation.

Corporations.

Double taxation.

Double taxation--Treaties.

Physical Description:

1 online resource (67 p.)

Place of Publication:

Paris : OECD Publishing, 2014.

Language Note:

English

Summary:

This report identifies the issues arising from the development of a multilateral instrument that modifies bilateral tax treaties. Without a mechanism for swift implementation, changes to model tax conventions only widen the gap between the content of these models and the content of actual tax treaties. Developing such a mechanism is necessary not only to tackle base erosion and profit shifting, but also to ensure the sustainability of the consensual framework to eliminate double taxation. This is an innovative approach with no exact precedent in the tax world, but precedents for modifying bilateral treaties with a multilateral instrument exist in various other areas of public international law. Drawing on the knowledge of experts in public international law and taxation, the Report concludes that a multilateral instrument is desirable and feasible, and that negotiations for such an instrument should be convened quickly.

Contents:

Foreword; Table of contents; Abbreviations and acronyms; Executive summary; Introduction; A multilateral instrument is desirable and feasible; Developing a multilateral instrument is desirable: The benefits are numerous, while burdens can be addressed or avoided; Developing a multilateral instrument is feasible: Legal mechanisms are available to achieve a balanced instrument that addresses the technical and political challenges; Note

The nature of the treaty-related BEPS measures will facilitate the conclusion of a targeted multilateral instrument, which could be further expanded at a later dateNext steps: Scoping the International Conference; Annex A. A toolbox for a multilateral instrument for the swift implementation of BEPS measures; Executive summary; Introduction; A Multilateral instrument can modify the network of bilateral tax treaties; A multilateral instrument can provide flexibility in the level of commitment; A multilateral instrument can ensure transparency and clarity of commitments; Conclusion; Notes

Bibliography

Notes:

Description based upon print version of record.

Includes bibliographical references.

ISBN:

92-64-21925-0