Multilateral Instrument (MLI) is an instrument that implements tax treaty-related measures of BEPS. Article 7 of MLI is made by the recommendations of OECD and G20 in the BEPS Action 6 Report. Structure of Article 7 of MLI Paragraph 1 of Article 7 Paragraph 1 of Article 7 covers the principal purpose test, where the … Continue reading Everything about Article 7 of MLI | Treaty Abuse
In the below flowchart we have tried to simplify the interaction between the Treaty Specific Anti Abuse Rules, Principal Purpose Test, Limitation of Benefits Rules, and General Anti Abuse Rules. It is for quick review only, and in-depth analysis is suggested while applying for real-life cases.
Simplified Limitation of Benefit (SLOB), also known as Specific Anti-Abuse Rules, is one of the three alternative rules provided in the BEPS Action 6 Report on Preventing the tax treaty benefits in inappropriate circumstances. Simplified Limitation of Benefits is an objective test to define the normative criteria and attributes that determine whether the income recipient … Continue reading Everything about Simplified Limitation of Benefits | SLOB Test
BEPS Action 6 Report on Preventing the tax treaty benefits in inappropriate circumstances includes three alternative rules to address situations of treaty abuse. Firstly, a general anti-abuse rule (GAAR) is based on the principal purpose of transactions or arrangements. The second a simplified version of specific anti-abuse rules (SAAR), and the third a detailed version … Continue reading Principal Purpose Test | Paragraph 1 of Article 7 of MLI