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Author : NATHALIE. BRAVO
Publisher :
ISBN 13 : 9789087225902
Total Pages : pages
Book Rating : 4.03/5 ( download)
Download or read book MULTILATERAL INSTRUMENT FOR UPDATING THE TAX TREATY NETWORK. written by NATHALIE. BRAVO and published by . This book was released on 2020 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt:
Author : Sergio André Rocha
Publisher : Kluwer Law International B.V.
ISBN 13 : 9041194290
Total Pages : 401 pages
Book Rating : 4.99/5 ( download)
Download or read book A Multilateral Convention for Tax written by Sergio André Rocha and published by Kluwer Law International B.V.. This book was released on 2021-11-29 with total page 401 pages. Available in PDF, EPUB and Kindle. Book excerpt: The Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) is the most forceful multilateral initiative to coordinate tax regimes on a worldwide basis since the dawn of modern income taxation over a century ago. This book evaluates two radically opposed viewpoints on the convention—a momentous and revolutionary paradigm shift versus a mechanism that merely continues an ongoing flow of limited policy coordination—with detailed investigations that bring to life the hopes and the realities of the current era of multilateral tax cooperation. Bringing together authors from national jurisdictions across the globe to scrutinize the MLI and its likely future ramifications, the book provides in-depth commentary and analysis in the following sequence: first, a comprehensive discussion of the design and goals of the MLI as a treaty and an institutional framework; second, an overview of the structure of the convention and its take-up across the globe to date; and third, the substantive implementation of the MLI with a wide range of country reports. Practice areas covered include tax law, international law, and international relations. The legal workings and implications of the MLI might still seem mysterious to those whose daily work is impacted by it, and there is as yet little jurisprudence regarding its legal nature or ultimate effect on the bilateral treaties coming within its scope. For these reasons, this pathbreaking book will be warmly welcomed by in-house counsel and law firms advising cross-border investors and firms; nongovernmental organizations involved in policy analysis and issue advocacy; researchers working on technical areas of international tax law; and lawyers interested in international policymaking, including the creation and diffusion of consensus-based fiscal and related regulatory norms across jurisdictions of differing development levels.
Author : Michael Lang
Publisher : Kluwer Law International B.V.
ISBN 13 : 9041189165
Total Pages : 296 pages
Book Rating : 4.65/5 ( download)
Download or read book The OECD Multilateral Instrument for Tax Treaties written by Michael Lang and published by Kluwer Law International B.V.. This book was released on 2016-04-24 with total page 296 pages. Available in PDF, EPUB and Kindle. Book excerpt: The Multilateral Instrument (MLI) proposed in OECD BEPS Action 15 will lead to the modification of numerous tax treaties. As tax treaties can have different wording, terminology and structure, a great challenge is to find a proper way to accomplish their modification without distorting the underlying framework or triggering undesirable effects. This book analyses the MLI, which was signed by over seventy jurisdictions on 7 June 2017. The topics covered include: • the procedural mechanisms on how the new measures to prevent base erosion and profit shifting (BEPS) will interact with and complement existing tax treaties; • the scope of the MLI in order to ascertain which tax treaties and taxes are covered; • the interpretation of terms used in the MLI and the relationship between the languages used in the MLI and in the particular tax treaties; • the implementation of the minimum standard through the MLI, as well as how states can exercise various options offered by the MLI and reserve the right not to apply certain provisions of the MLI; • the legal consequences of the exercise of options and reservations for the other states; • the notification procedure through which states declare their choices; and • the possibilities and procedure for withdrawal from the obligations entered into upon signing the MLI. Finally, the book discusses whether the mechanism of the MLI can serve as a role model for future changes to the OECD Model Convention. The book incorporates the analyses of leading scholars and practitioners dealing with international tax matters. Critical insights are offered for academics, practitioners, tax officials and judges who deal with or are interested in the field of international taxation.
Author : D.M. Broekhuijsen
Publisher : Springer
ISBN 13 : 9789041198723
Total Pages : 298 pages
Book Rating : 4.25/5 ( download)
Download or read book Looking Ahead:Inter-National Law in 21st written by D.M. Broekhuijsen and published by Springer. This book was released on 2002-03-21 with total page 298 pages. Available in PDF, EPUB and Kindle. Book excerpt: Many states have set out to develop a multilateral tax instrument with the purpose of amending bilateral treaties in a quick and comprehensive fashion. The recent adoption by as many as a hundred jurisdictions of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (the OECD Multilateral Instrument) is the most prominent step in this direction. This book provides not only a detailed analysis of the OECD Multilateral Instrument but also discusses in depth the far-reaching implications of the international tax reform currently under way. The author shows how the BEPS Project has merely unveiled the problems related to bilateral tax relationships and articulates initiatives to ensure the sustainability of a multilateral consensus. Drawing on the fields of international law, international relations, and political science, he develops a design strategy, complete with draft clauses, that fundamentally transforms the way states cooperate in the field of international tax, effectively addressing such problems as the following: – the need for collective action; – the problem structure of multilateral tax cooperation; – the relevance of the OECD Model Tax Convention and Commentaries thereon; – the place, position and operation of the OECD Multilateral Instrument; – non-OECD member countries; and – treaty shopping. The principled and pragmatic structural solution presented would allow policymakers to continuously adapt and respond to the rapidly evolving nature of the global economy. The author’s original research and his recommendations for future development of the topic offer deeply informed guidance to policymakers, practitioners and other tax professionals, and academics.
Author : Georg Kofler
Publisher :
ISBN 13 : 9789087227203
Total Pages : 1014 pages
Book Rating : 4.05/5 ( download)
Download or read book The Implementation and Lasting Effects of the Multilateral Instrument written by Georg Kofler and published by . This book was released on 2021 with total page 1014 pages. Available in PDF, EPUB and Kindle. Book excerpt: Action 15 of the BEPS Project ?The Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting? - the Multilateral InstruƯment (MLI) ? is a multilateral convention that swiftly modifies the application of existƯing bilateral tax treaties without the need to renegotiate each treaty individually. It does not replace the existing tax treaties but rather modifies their application with the aim to reduce the opportunities for tax avoidance by multinational enterprises, counter treaty abuse and improve the dispute resolution mechanism, providing flexibility according to the different treaty policies and positions chosen by countries. The MLI was finalized in November 2016, and a first signing ceremony was held in Paris on 6 June 2017. A total of 76 jurisdictions signed it at this first ceremony. In the meantime, it has grown to cover almost 100 jurisdictions. The aim of this book is to provide tax authorities, policymakers, courts and practitioners with an overview of the countries? positions and experiences reƯgarding the impact of the MLI on their tax treaty network, as well as other issues on the implementation of the convention with respect to policy options, reservations, and legal and constitutional concerns.00The book comprises 34 national reports from countries across the globe and is the outƯcome of an alternative non-physical interaction between national reporters and authors. This was due to the special COVID-19 situation lived during 2020, serving as a substitute for the prepared conference on the MLI that should have taken place from 2 to 4 July 2020 in Rust, Burgenland, Austria. A general report highlights the most important findings.
Author : OECD
Publisher : OECD Publishing
ISBN 13 : 9264219250
Total Pages : 67 pages
Book Rating : 4.50/5 ( download)
Download or read book OECD/G20 Base Erosion and Profit Shifting Project Developing a Multilateral Instrument to Modify Bilateral Tax Treaties written by OECD and published by OECD Publishing. This book was released on 2014-09-16 with total page 67 pages. Available in PDF, EPUB and Kindle. Book excerpt: Produced by the OECD/G20 Base Erosion and Profit Shifting Project, this report identifies the issues arising from the development of a multilateral instrument that modifies bilateral tax treaties.
Author : Dirk M. Broekhuijsen
Publisher :
ISBN 13 : 9789041198488
Total Pages : 298 pages
Book Rating : 4.82/5 ( download)
Download or read book A Multilateral Tax Treaty written by Dirk M. Broekhuijsen and published by . This book was released on 2018-03 with total page 298 pages. Available in PDF, EPUB and Kindle. Book excerpt: Many states have set out to develop a multilateral tax instrument with the purpose of amending bilateral treaties in a quick and comprehensive fashion. The recent adoption by as many as a hundred jurisdictions of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (the OECD Multilateral Instrument) is the most prominent step in this direction. This book provides not only a detailed analysis of the OECD Multilateral Instrument but also discusses in depth the far-reaching implications of the international tax reform currently under way. The author shows how the BEPS Project has merely unveiled the problems related to bilateral tax relationships and articulates initiatives to ensure the sustainability of a multilateral consensus. Drawing on the fields of international law, international relations, and political science, he develops a design strategy, complete with draft clauses, that fundamentally transforms the way states cooperate in the field of international tax, effectively addressing such problems as the following: - the need for collective action; - the problem structure of multilateral tax cooperation; - the relevance of the OECD Model Tax Convention and Commentaries thereon; - the place, position and operation of the OECD Multilateral Instrument; - non-OECD member countries; and - treaty shopping. The principled and pragmatic structural solution presented would allow policymakers to continuously adapt and respond to the rapidly evolving nature of the global economy. The author's original research and his recommendations for future development of the topic offer deeply informed guidance to policymakers, practitioners and other tax professionals, and academics.
Author :
Publisher :
ISBN 13 :
Total Pages : 48 pages
Book Rating : 4.41/5 ( download)
Download or read book Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting written by and published by . This book was released on 2016 with total page 48 pages. Available in PDF, EPUB and Kindle. Book excerpt: More than 100 jurisdictions have concluded negotiations on a multilateral instrument (MLI) that will swiftly implement a series of tax treaty measures to update international tax rules and lessen the opportunity for tax avoidance by multinational enterprises. The new instrument will transpose results from the OECD/G20 Base Erosion and Profit Shifting (BEPS) Project into more than 2000 tax treaties worldwide. A signing ceremony will be held in June 2017 in Paris.
Author : J.A. Becerra
Publisher :
ISBN 13 :
Total Pages : pages
Book Rating : 4.47/5 ( download)
Download or read book The Interpretation and Application of the Preamble and Article 6(1) of the OECD Multilateral Instrument in the Context of North American Tax Treaty Networks written by J.A. Becerra and published by . This book was released on 2018 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: This article examines the influence, if any, of the Preamble and article 6(1) of the OECD Multilateral Instrument (MLI), with particular focus on the extent to which they will modify the interpretation and application of the existing tax treaties in Canada, Costa Rica and Mexico.
Author : J.A. Becerra
Publisher :
ISBN 13 :
Total Pages : pages
Book Rating : 4.11/5 ( download)
Download or read book A Practical Approach to Determine the Influence of the OECD Multilateral Instrument on North American Tax Treaty Networks written by J.A. Becerra and published by . This book was released on 2017 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: This article examines the practical influence of the OECD Multilateral Instrument (MLI), with particular focus on the extent to which it will modify, if at all, and affect the interpretation and application of the existing tax treaties of selected North American countries, i.e. Canada, Mexico and the United States.
