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Application of Article 6 (Purpose of a Covered Tax Agreement) of the Multilateral Instrument to Covered Tax Agreements

Part I – Introduction of Article 6

Articles 3 to 17 under Part II to V of the MLI provisions are substantive provisions addressing the BEPS issues. The substantive provisions have the following common structure: (i) operative clauses, (ii) compatibility clauses, (iii) reservation clauses and (iv) notification clauses.

The structure of Article 6 consists of a primary statement in the preamble texts of a covered tax agreement and an opt-in provision to enhance the purpose and object of the primary statement. The detailed structure of Article 6 is set out below:

  • Article 6(1) - Operative clause
  • Article 6(2) - Compatibiltiy clause
  • Article 6(3) - Opt-in clause
  • Article 6(4) - Reservation clause
  • Article 6(5) - Notification clause giving legal relevance to Article 6(2)
  • Article 6(6) - Notification clause giving legal relevance to Article 6(3)
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Content provided by China Tax & Investment Consultants Ltd
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