Article 6 of MLI introduces changes in the Preamble of the Covered Tax Agreements. It is a minimum standard as recommended under BEPS Action 6 report. We have discussed in detail the preamble stated under Article 6 of MLI in our previous post. Click here to read it. MLI preamble will be in place of … Continue reading Summary of changes to Preamble | Article 6 | MLI
Category: Decision Tree
Elimination of double taxation – Article 5 of MLI
Article 5 of the MLI contains provisions that provide three options for the elimination of double taxation. Countries may choose to address cases of double non-taxation that may where countries use the exemption method to prevent double taxation of income that is not taxed in the State of the source. OECD model convention provides two … Continue reading Elimination of double taxation – Article 5 of MLI
Dual Resident Entities | Article 4 | Complete flowchart
Article 4 of MLI provides a tie-breaker rule for the dual resident entities for determining their tax residence. A company is easily considered tax resident in two different states simultaneously when it registers under one state’s laws but has the place of effective management in another. It is generally understood that a place of effective … Continue reading Dual Resident Entities | Article 4 | Complete flowchart
Covered Tax Agreement | Article 2 Decision Tree
For easy understanding of the applicability of Article 2(1)(a)(ii) of MLI, we present the decision tree diagram (flow chart). It is a quick summary of Article 2 of Multilateral Instrument. As per Article 2(1)(a)(ii) of MLI, the MLI will modify only those double tax agreements that : Each Party has specifically identified and listed in … Continue reading Covered Tax Agreement | Article 2 Decision Tree