The data compiled for this peer review demonstrate that the BEPS Multilateral Instrument has been the tool used by the vast majority of jurisdictions that have begun implementing the Action 6 minimum standard, and that the MLI has started to impact tax treaties of jurisdictions that have ratified it.
The new tax treaty implements the minimum standards in accordance with the OECD’s project on base erosion and profit shifting.
The new treaty will be effective from January 1, 2021.
The tax treaty applies from January 1, 2020.
The tax treaty will become effective after both countries have completed their respective domestic procedures.
The tax treaty and Protocol implement the BEPS minimum standards to tackle tax planning strategies that exploit gaps and mismatches in tax rules.
The tax treaty will enter into force after both countries have completed their respective internal procedures.
Japan and Peru have “in principle” agreed to conclude a tax treaty.
The Protocol will be effective for requests for information made on or after the date of entry into force for tax years on or after January 1, 2009.
Mandatory binding arbitration clause is included in the tax treaty protocols to resolve tax treaty disputes.
The treaty protocol provides for a low withholding tax rate of five percent for royalty and interest payments. An arbitration clause is also included to increase legal certainty for taxpayers.
The treaty will be effective from April 1, 2019.
An arbitration clause is included in the new tax treaty to resolve double taxation disputes.
The tax treaty provides for a low withholding tax rate of five percent for dividend payments. Interest, royalties, and fees are subject to a low withholding tax rate of ten percent.
India has signed a Protocol to amend its tax treaty with China.
The Protocol incorporates changes required to implement tax treaty-related minimum standards agreed under the base erosion and profit shifting (BEPS) project.
Japan and Spain signed a new tax treaty on October 16. The tax treaty wholly amends the existing tax treaty between Japan and Spain, which entered into force in 1974.
As per the new tax treaty, a withholding tax exemption applies to investment income from interest and royalties. Withholding tax on dividends is also exempt in certain situations.
Japan and Croatia signed a new tax treaty on October 19.
The new tax treaty provides for a reduced withholding tax on dividends, interest, and royalties. In some case, these are exempt.
The tax treaty between Japan and Iceland will enter into force on October 31, 2018, Japan’s Finance Ministry has announced.
The protocol to amend the Switzerland-Latvia tax treaty entered into force on September 3, 2018, and will take effect from January 1, 2019.
The Swiss Federal Council on August 22 adopted the dispatch concerning a protocol of amendment to the Swiss-UK tax treaty for the attention of Parliament.
The Swiss Federal Council on August 15 adopted the dispatch on the tax treaty with Saudi Arabia.
Japan and Colombia have completed tax treaty negotiations, Colombia’s Finance Minister, Mauricio Cárdenas, announced on July 30.
The tax treaty between Singapore and Nigeria will enter into force on November 1, 2018, and will take effect on January 1, 2019.
Guernsey has signed a new tax treaty with the UK. The new tax treaty replaces the one that has been in force since 1951.
The new tax treaty is based, broadly, on the OECD Model Tax Convention, which Guernsey has generally followed in its negotiations with other jurisdictions in recent years. The text of the tax treaty incorporates some of the recent international standards designed to prevent base erosion and profit shifting (BEPS).
The governments of UK and Isle of Man signed a new tax treaty on July 2.
The tax treaty is based on the latest OECD Model Tax Convention and includes provisions to reflect the OECD’s base erosion and profit shifting (BEPS) measures.
The UAE has newly joined the OECD’s Inclusive Framework on base erosion and profit shifting (BEPS).
The Inclusive Framework on BEPS allows interested countries and jurisdictions to work with the OECD and Group of Twenty nations on monitoring the implementation of the BEPS proposals.
India’s Union Cabinet has approved revision of the country’s tax treaty with Qatar.
The revised tax treaty includes a limitation of benefits clause to prevent treaty shopping. It meets the base erosion and profit shifting (BEPS) minimum standards on treaty abuse (BEPS Action 6) and mutual agreement procedure (BEPS Action 14).
The Indian Government has approved the country’s tax treaty with Iran.
The tax treaty is in line with the ones entered into by India with other countries. The proposed treaty also meets tax treaty-related minimum standards proposed under the OECD’s base erosion and profit shifting project, in which India is participating on an equal footing.
An amending Protocol to the UK-Mauritius tax treaty was signed on February 28, 2018.
Singapore and Tunisia have signed a tax treaty, which provides for low withholding tax rates and a detailed exchange of information provision.
On February 19, 2018, India gazetted a revised tax treaty with Kenya. The revised treaty was signed by both countries in July 2016.
Japan and Spain have agreed in principle to the text of a new tax treaty.
The new tax treaty will replace the existing treaty between both countries, which entered into force in 1974.
India on February 17 signed a tax treaty with Iran. The treaty is similar to the ones entered into by India with other countries.
Ireland and Ghana signed a new tax treaty on February 7, 2018. The procedures to ratify the treaty are underway.
Ireland is also negotiating and renegotiating existing treaties with foreign jurisdictions.
According to the tax authority, Ireland’s existing treaty base will also be updated to incorporate provisions set out in the Multilateral Convention to implement tax treaty-related measures to prevent base erosion and profit shifting.
By Alex Cooper
US Congressman David Valadao has urged Treasury Secretary Steven Mnuchin to renegotiate the US tax treaty with Armenia with a view to ending double taxation currently imposed on businesses in both countries.
By Alex Cooper
On February 7, 2018, the Indian Government approved the signing and ratification of a protocol to amend the country’s tax treaty with China.
By Alex Cooper
On February 5, 2018, the UAE President issued a federal decree ratifying the country’s tax treaty with Paraguay.
Italy and Colombia have signed a new tax treaty in line with the base erosion and profit shifting (BEPS) project.
A revised tax treaty between Singapore and Sri Lanka entered into force on December 31, 2017.
The new tax treaty between Ireland and Kazakhstan became effective on January 1, 2018.
The tax treaty, which was signed by both countries in April 2017, entered into force on December 29, 2017.