International Anti-Corruption Commitments

Title of the document

OECD Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting

Issuing body

OECD

Brief description

The Convention offers measures for governments to close the gaps in existing international tax rules by transposing results from the OECD/G20 BEPS Project into bilateral tax treaties worldwide. It modifies the application of thousands of bilateral tax treaties concluded to eliminate double taxation. It also implements agreed minimum standards to counter treaty abuse and to improve dispute resolution mechanisms while providing flexibility to accommodate specific tax treaty policies.

Relevant excerpts

Article 3 – Transparent Entities

Article 4 – Dual Resident Entities

Article 5 – Application of Methods for Elimination of Double Taxation

Article 7 – Prevention of Treaty Abuse

Article 8 – Dividend Transfer Transactions

Article 10 – Anti-abuse Rule for Permanent Establishments Situated in Third Jurisdictions

Article 11 – Application of Tax Agreements to Restrict a Party’s Right to Tax its Own Residents