Market leading insight for tax experts
View online issue

Quarterly tax treaty briefing: Winter 2017

Speed read

Recent highlights have been dominated by new and amended treaties reflecting BEPS recommendations, including publication of the long awaited multilateral instrument (MLI).The UK has already been active in adopting into some of its treaties both the Action 6 minimum standard preamble that a treaty is not to be used for tax avoidance, and the principal purpose test. It has also adopted the Action 6 ‘savings’ clause, allowing it to tax residents despite treaty terms; Action 2, concerning fiscally transparent entities; and Action 7, concerning PE avoidance through anti-fragmentation. These changes reflect the UK government’s policy choices in relation to the MLI.

If you or your firm subscribes to, please click the login box below:

If you do not subscribe but are a registered user, please enter your details in the following boxes:

Alternatively, you can register free of charge to read a limited amount of subscriber content per month.
Once you have registered, you will receive an email directing you back to read this article in full.
Please reach out to customer services at +44 (0) 330 161 1234 or '' for further assistance.