Autore: Piergiorgio Valente
Tipologia: Articolo in rivista
Titolo rivista: Intertax
Anno pubblicazione: 2017
ISSN:0165-2826
Abstract:
The release of the Multilateral Instrument constitutes an important step towards the most significant re-write of international tax rules in a century. It is the multilateral convention enabling the simultaneous amendment of more than 3,000 existing bilateral conventions for the avoidance of double taxation. It aims at eliminating loopholes and mismatches among them, which are susceptible to allow aggressive tax planning. In thirty-nine articles, it implements measures indicated in Actions 2, 6, 7 and 14 of the Base Erosion and Profit Shifting (BEPS) Project, regarding hybrid mismatches, treaty abuse, artificial avoidance of permanent establishment status and dispute resolution of international tax disputes.
URL: http://www.gebpartners.it/articles-eng/2017/3/20/beps-action-15-release-of-multilateral-instrument