THE OECD is consulting on how to tackle the challenges involved in implementing a multilateral instrument that will apply treaty-related changes when combating base erosion and profit shifting.
The public discussion draft on BEPS Action 15 is seeking comments that should be focused solely on technical issues of implementation and on issues related to the development of a MAP (mutual agreement procedure) arbitration provision, rather than on the scope of the provisions to be covered in the multilateral instrument or on the substance of the underlying BEPS outputs.
Input is requested on the technical issues that may arise from implementing the treaty-related BEPS measures in the context of the network of existing bilateral tax treaties.
The purpose of the multilateral instrument is to “modify existing bilateral tax treaties in order to swiftly implement the tax treaty measures developed in the course of the OECD-G20 BEPS project.”
In particular, comments are requested with respect to technical issues that should be taken into account in adapting the BEPS measures to modify or supersede existing provisions of bilateral tax treaties that may vary from the OECD model, including: existing provision or types of provisions that serve the same purpose as the BEPS measures and that would need to be replaced and existing provisions or types of provisions that are similar to BEPS measures but that would need to be retained
“The consultation has been organised around certain key technical issues and questions relating to the development of the instrument on which public input would be useful,” the OECD notes.
The group began its work on 27 May 2015, and aims to conclude its work and open the multilateral instrument for signature by 31 December 2016.
Persons and organisations who submit comments on this document are invited to indicate whether they wish to speak in support of their comments at a public consultation meeting that is scheduled to be held in Paris at the OECD Conference Centre on 7 July 2016
Comments and input should be submitted by 30 June 2016 at the latest, and should be sent by email to email@example.com
For more details of the consultation, click here.
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