A country has a right to tax the income of its residents and the income of PE of non-resident MNEs. However, through a web of tax planning and corporate structures, many large corporates have artificially avoided the establishment of PE through Commissionnarie Arrangements (covered in Article 12 of MLI) and similar strategies. An OECD study … Continue reading Article 12 of MLI | Avoidance of PE through Commissionnarie Arrangements
Category: BEPS
Article 3 of MLI – Fiscally transparent entities
Article 3 of the Multilateral Convention directs taxation of income of the fiscally transparent entities
Article 3(1) of MLI – Taxation of income derived by or through fiscally transparent entities
Article 3(1) is the primary provision of Article 3. It reflects BEPS Action Plan 2 measure that addresses income earned through fiscally transparent entities. To understand this provision’s genesis, we need to look into the issues of fiscally transparent entities while availing the treaty benefits. Whether treaty applies to a Fiscally transparent entity? Article 1 … Continue reading Article 3(1) of MLI – Taxation of income derived by or through fiscally transparent entities
Introduction to Part II of Multilateral Convention | Hybrid Mismatch
Introduction to Hybrid Mismatch arrangements
Article 1 and 2 of Multilateral Convention
Article 1 and 2 of the Multinational convention
Checklist for applicability of Multi Lateral Instruments Provisions to existing tax treaty
Checklist for applicability of Multi Lateral Instruments Provisions to existing tax treaty
Understanding Compatibility Clause
Compatibility clause under the Multilateral Instruments
Date of Entry into Effect – Overview
Understanding the Date of Entry into Effect of the Multi Lateral Instruments
Date of Entry into Force under Multilateral Instruments
Article 34 of Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting also known as MLI
Understanding what is Covered Tax Agreement “CTA”
Complete understanding of Covered Tax Agreements