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The Implementation and Lasting Effects of the Multilateral Instrument

The Implementation and Lasting Effects of the Multilateral Instrument
Author: Georg Kofler
Publisher:
Total Pages: 1014
Release: 2021
Genre:
ISBN: 9789087227203
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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.

The OECD Multilateral Instrument for Tax Treaties

The OECD Multilateral Instrument for Tax Treaties
Author: Michael Lang
Publisher: Kluwer Law International B.V.
Total Pages: 296
Release: 2016-04-24
Genre: Law
ISBN: 9041189165
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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.

Multilateral Cooperation in Tax Law

Multilateral Cooperation in Tax Law
Author: Martin Klokar
Publisher: Linde Verlag GmbH
Total Pages: 357
Release: 2023-10-03
Genre: Law
ISBN: 3709412986
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An in-depth analysis of various aspects of multilateral cooperation in tax law Tax evasion and aggressive tax planning causing base erosion and profit shifting (BEPS) has been a widely discussed topic among academics and tax policy makers over the past decades. Increasing globalization and digitalization have contributed to the intensification of this issue in recent years. At the same time, states continue to largely insist on their sovereignty in the area of tax law. However, due to their cross-border nature, issues related to BEPS are shared problems among the states and can typically not be solved by a single nation. Therefore, multilateral cooperation represents an option to build a bridge between the states’ demand for sovereignty and the problems caused by BEPS. In this regard, the OECD, the UN, and the EU play an important role in introducing international tax standards in an attempt to effectively address tax evasion and aggressive tax planning in many ways. The interaction and cooperation between different international, supranational (EU), and regional organizations is an ongoing process. In this context, the topic "Multilateral Cooperation in Tax Law" was selected as the general topic for the master’s theses of the part-time 2021-23 class of the postgraduate LL.M. programme in International Tax Law at WU (Vienna University of Economics and Business). This volume aims to develop academic insights, provide practical guidance, and enable an in-depth analysis of various aspects of this topic. The book is divided into four parts. The first part deals with a general overview of the understanding of multilateral cooperation, the background that led to the need for multilateral cooperation and the different stakeholders that play a relevant role in it. While the chapters included in the second part focus on the most important developments on an international level (OECD and UN), the chapters encompassed in the third part analyse the multilateral cooperation initiatives of the EU. Finally, the chapters included in part four deal with selected issues related to multilateral cooperation in tax law, including mutual assistance and exchange of information, dispute resolution mechanisms, and measures in digitalized businesses.

US Perspectives on the Multilateral Instrument

US Perspectives on the Multilateral Instrument
Author: M. Herzfeld
Publisher:
Total Pages:
Release: 2018
Genre:
ISBN:
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In this article the author explains why the USA did not sign the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI).

A Practical Approach to the Multilateral Instrument

A Practical Approach to the Multilateral Instrument
Author: S. McDonnell
Publisher:
Total Pages:
Release: 2020
Genre:
ISBN:
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This article provides a step-by-step guide to use when considering the impact of the OECD's Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI).

A Multilateral Instrument for Updating the Tax Treaty Network

A Multilateral Instrument for Updating the Tax Treaty Network
Author: Nathalie Bravo
Publisher:
Total Pages: 339
Release: 2020
Genre: Double taxation
ISBN: 9789087225919
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A precise and in-depth analysis of the Multilateral Instrument and of how it impacts the tax treaty network by implementing the treaty-related BEPS measures.

Justice, Equality and Tax Law

Justice, Equality and Tax Law
Author: Nevia Čičin-Šain
Publisher: Linde Verlag GmbH
Total Pages: 541
Release: 2022-10-05
Genre: Law
ISBN: 3709412587
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An in-depth analysis of the specific aspects of justice, equality and tax law "Justice, Equality and Tax Law" is a topic that is both old and new at the same time. Even if the society changes, the demands that tax needs to be just and equal seem to be immutable. What changes, of course, is the perception of the content of those demands. International taxation post-BEPS has been fraught with new challenges that warranted urgent responses. These challenges were mainly provoked by the unprecedented rise of the digital economy which truly marked a change in the way business is conducted, how value is created, and how goods and services are produced and consumed. Digitalization, in turn, had repercussions on all aspects of taxation - direct taxation, indirect taxation, and even tax procedures. For instance, the quest for more justice and equality in profit taxes was the reason why, in October 2021, a historical deal based on a two-pillar solution to address the tax challenges arising from the digitalization of the economy was negotiated within the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting and agreed upon by 137 member countries. It was also the motive behind the shift from a typical vendor collection model to an intermediary collection model supported by centralized registration points in indirect taxes, notably the VAT/GST. Abundant data from the European Union or the OECD signalized an ever-increasing gap between expected VAT revenues and VAT actually collected, making it obvious that the classical system of VAT/GST collection was unable to respond to challenges posed by the digital economy. Therefore, new solutions based on the participation of digital platforms as intermediaries had been introduced. Finally, new technologies, such as blockchain, paved new avenues in enhancing tax compliance. In this context, this volume entitled "Justice, Equality, and Tax Law" contains not only a selection of the best master ́s theses of the full-time LL.M. programme in 2021/2022 but also represents an in-depth analysis of various aspects of this evergreen topic.

Article 12B UN Model Convention 2021

Article 12B UN Model Convention 2021
Author: Christian Knotzer
Publisher: Kluwer Law International B.V.
Total Pages: 551
Release: 2024-07-15
Genre: Law
ISBN: 940352488X
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This groundbreaking book – a major contribution addressing the imperative to find a solution to what has been labelled as the Tax Challenges Arising from the Digitalization of the Economy – provides the first comprehensive analysis of Article 12B of the UN Model Double Taxation Convention 2021, a model distributive rule for ‘Income from Automated Digital Services’. In extensive detail, the author thoroughly examines the article’s underlying principles, its individual provisions, the tax policy context that surrounds it, how it might be applied, and what its strengths and weaknesses are. The author’s analysis (which includes a paragraph-by-paragraph discussion of the article and examines its Commentary in extensive detail) covers all aspects of the article and its significance, including the following: how to reconcile the approach taken by Article 12B UN Model Convention with general principles underlying the coordination of taxing claims; legal and tax policy relation to other provisions of the UN Model Convention and to the OECD/Inclusive Framework Pillar One/Amount A; influence of developing countries in forums of international tax coordination; the value of country positions and minority views in Model Conventions; categories of digital services; the novel option for annual net taxation in Article 12B(3) UN Model Convention; and the proposal for a UN fast-track instrument. It is not surprising that the ubiquitous digitalization of the economy has led to a widespread sense of unease in the international tax community. Practitioners and policymakers who face this issue in their day-to-day work will greatly appreciate this book’s clear explanation of how Article 12B UN Model Convention works and benefit from its consideration of how it is likely to be implemented in the international double taxation treaty network.

Action Plan on Base Erosion and Profit Shifting

Action Plan on Base Erosion and Profit Shifting
Author: OECD
Publisher: OECD Publishing
Total Pages: 44
Release: 2013-07-19
Genre:
ISBN: 9264202714
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This action plan, created in response to a request by the G20, identifies a set of domestic and international actions to address the problems of base erosion and profit sharing.

Mobilization Effects of Multilateral Development Banks

Mobilization Effects of Multilateral Development Banks
Author: Chiara Broccolini
Publisher: International Monetary Fund
Total Pages: 51
Release: 2019-02-15
Genre: Business & Economics
ISBN: 1498301061
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We use loan-level data on syndicated lending to a large sample of developing countries between 1993 and 2017 to estimate the mobilization effects of multilateral development banks (MDBs), controlling for a large set of fixed effects. We find evidence of positive and significant direct and indirect mobilization effects of multilateral lending on the number of deals and on the total size of bank inflows. The number of lending banks and the average maturity of syndicated loans also increase after MDB lending. These effects are present not only on impact, but they last up to three years and are not offset by a decline in bond financing. There is no evidence of anticipation effects and the results are not driven by confounding factors, such as the presence of large global banks, Chinese lending and aid flows. Finally, the economic effects are sizable, suggesting that MBDs can play a vital role to mobilize private sector financing to achieve the goals of the 2030 Development Agenda.