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
Tag: BEPS Action Plan 2
Introduction to Part II of Multilateral Convention | Hybrid Mismatch
Introduction to Hybrid Mismatch arrangements
What is Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting?
Quick overview about the Multilateral Instruments also known as MLI also known as Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting