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Multilateral Instrument: Analysis on the Application of the Entry-into-Force and the Entry-into-Effect Articles to Covered Tax Agreements

The Multilateral Convention to Implement Tax Related Measures to Prevent Base Erosion and Profit Shifting (the multilateral Instrument, the MLI), developed by the OECD and endorsed by the G20, offers concrete solutions for governments to close the gaps in existing international tax rules by transposing results from the OECD/G20 BEPS Project into bilateral tax treaties worldwide. The MLI modifies the application of thousands of bilateral tax treaties concluded to eliminate double taxation without creating opportunity for double non-taxation.

The MLI has been designed to strengthen existing tax treaties concluded among its parties without the need for burdensome and time-consuming bilateral renegotiations. It will modify existing bilateral tax treaties to swiftly implement the tax treaty measures developed in the course of the OECD/G20 BEPS Project.

In what follows, this analysis will cover Article 34 (entry-into-force) and Article 35 (entry-into-effect). It will also cover the use of opt-in provisions, opt-out provisions (reservations), and alternative provisions within the contexts of Article 35.

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Content provided by China Tax & Investment Consultants Ltd
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