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On May 3 the Conference of the Parties to the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting approved an opinion titled "Interpretation and Implementation Questions," ...

In negotiating a tax treaty, both parties can discuss and cover every topic and insert it in the agreement or protocol.

Both Japan and Zealand opts in for Article 9(4), and both of the two contracting states have made notification to the Depositary, pursuant to Article 9(8) of the MLI.

This paper will focus on Article 16 - mutual agreement procedure (the MAP) and will be organized in the following way:

Article 6(1) sets the minimum standard for all Parties that have committed themselves to the OECD/G20 BEPS package.

Article 35(4) provides that Article 16 (MAP) shall have effect with respect to a CTA for a case presented to the competent authority of a contracting jurisdiction on or after the latest of the dates on which the MLI ...

The definition of PE included in tax treaties is therefore crucial in determining whether a non-resident enterprise must pay income tax in another State.

In Section IV, the article ends with a conclusion that one can learn from understanding the MLI as an international convention.

To combat base erosion and profit-shifting practices and enhance cooperation in international taxation, the countries that have committed themselves to membership in the OECD inclusive framework...

The following is Part 3 of the above captioned article that specifically deals with How contracting jurisdictions apply Article 16 to their CTA's.

Note that this section illustrates how Article 16 works in practice from an Australian perspective.

The author examines how the choices by Japan of the option in the entry-into-effect provision interact with that chosen by 4 of the other contracting jurisdictions of the MLI, such as India...

The author examines how the choices by Japan of the option in the entry-into-effect provision interact with that chosen by 4 of the other contracting jurisdictions of the MLI, such as India, Iceland, Sweden and the United Kingdom.

Base erosion and profit shifting (BEPS) refers to tax planning strategies used by multinational enterprises that exploit gaps and mismatches in tax rules to avoid paying tax.

It is observed that except for India, 4 other contracting parties have chosen to opt-in for Article 7(4).

The 2015 Final Report on action 7 of the OECD/G20 BEPS Action Plan, titled "Preventing the Artificial Avoidance of Permanent Establishment Status", addresses the issue of artificial avoidance of permanent establishment status, ...

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 ...