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The BEPS multilateral convention: who loves SLOBs?

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The BEPS multilateral convention was signed by 68 countries on 7 June 2017. It will ultimately modify over 1,100 double tax treaties. The convention presented two options for countering ‘treaty abuse’ (following BEPS Action 6): a principal purpose test, very similar to the anti-avoidance rule included in UK treaties for years; and a US-style limitation on benefits article that had the potential to hinder much cross-border investment. However, the principal purpose test is the default position under the convention and very few states have opted for the limitation on benefits article, which means it is of limited relevance in practice.

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