On 24 November 2016, a group of over 100 jurisdictions decided
on a Multilateral Instrument (MLI) that will modify the application
of existing bilateral tax treaties to implement the tax treaty
measures developed through the OECD/G20 BEPS project. Depending on
the ratification process, the potential impact on over 2,000
existing bilateral tax treaties will be substantial. Jan Hein
Geertsma, Senior Tax Counsel, and Steffan Galesloot, Head of
Services Innovation, share all you need to know about the MLI.
KEY MEASURES
The MLI will modify existing bilateral tax treaties through the
following provisions:
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Hybrid mismatches
The MLI introduces optional treaty provisions to address hybrid
mismatches arising from differences in the tax classification of an
entity or an arrangement under the laws of two or more countries.
According to these provisions, no tax treaty benefits shall be
granted in case income isn't considered to be income of a
resident of one of the
