Sandy Bhogal and Kitty Swanson (Mayer Brown) consider the final output of action 15 of the OECD’s BEPS project and how this will apply to the UK.
Background
A number of BEPS action items – Action 2 (hybrid mismatch arrangements) Action 6 (treaty abuse) Action 7 (avoidance of permanent establishment (PE) status) and Action 14 (improving dispute resolution mechanisms) – aimed to develop tax treaty measures to address specific BEPS concerns. Action 15 proposed a multilateral instrument to facilitate the implementation of these treaty related measures across the extensive network of bilateral tax treaties (which totals more than 3 000 treaties) and thereby avoid the need for each treaty to be renegotiated separately.
After an initial report in September 2014 concluded that a multilateral instrument was both desirable and feasible the OECD’s Committee on Fiscal Affairs mandated the establishment of an ad hoc group to...
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Sandy Bhogal and Kitty Swanson (Mayer Brown) consider the final output of action 15 of the OECD’s BEPS project and how this will apply to the UK.
Background
A number of BEPS action items – Action 2 (hybrid mismatch arrangements) Action 6 (treaty abuse) Action 7 (avoidance of permanent establishment (PE) status) and Action 14 (improving dispute resolution mechanisms) – aimed to develop tax treaty measures to address specific BEPS concerns. Action 15 proposed a multilateral instrument to facilitate the implementation of these treaty related measures across the extensive network of bilateral tax treaties (which totals more than 3 000 treaties) and thereby avoid the need for each treaty to be renegotiated separately.
After an initial report in September 2014 concluded that a multilateral instrument was both desirable and feasible the OECD’s Committee on Fiscal Affairs mandated the establishment of an ad hoc group to...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
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