The OECD Multilateral Convention's operative text, done at Paris on 24 November 2016, modifies Covered Tax Agreements without bilateral renegotiation. Articles 3 to 5 address transparent entities, dual resident entities and methods for eliminating double taxation. Articles 6 to 11 counter treaty abuse through revised preamble wording, a principal purpose test and a Simplified Limitation on Benefits Provision. Articles 12 to 15 curb artificial avoidance of permanent establishment status, including commissionnaire arrangements and specific activity exemptions. Articles 16 and 17 strengthen the mutual agreement procedure and corresponding adjustments, while Part VI provides mandatory binding arbitration and Part VII governs reservations, notifications and entry into force.
Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting
Contents
Part I. Scope and Interpretation of Terms
Article 1 – Scope of the Convention
Article 2 – Interpretation of Terms
Part II. Hybrid Mismatches
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