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Table of Contents
Cover
Title
Copyright
Preface
Part One
Chapter 1: The Implementation and Lasting Effects of the Multilateral Instrument: General Report
1.1. Party to the MLI
1.2. Covered Tax Agreements
1.3. Hybrid mismatches
1.3.1. Transparent entities: Article 3 of the MLI
1.3.2. Dual-resident companies: Article 4 of the MLI
1.4. Application of methods for elimination of double taxation: Article 5 of the MLI
1.5. Treaty abuse
1.5.1. Preamble: Article 6 of the MLI
1.5.2. Main purpose test: Article 7 of the MLI
1.5.3. Simplified limitation on benefits: Article 7 of the MLI
1.5.4. Dividend transfer transaction: Article 8 of the MLI
1.5.5. Capital gains from alienation of shares or interests of entities deriving their value principally from immovable property: Article 9 of the MLI
1.5.6. Anti-abuse provision for permanent establishments situated in third jurisdictions: Article 10 of the MLI
1.5.7. Application of tax agreements to restrict a party's right to tax its own residents: Article 11 of the MLI
1.6. Avoidance of permanent establishment status
1.6.1. Artificial avoidance of permanent establishment status through commissionaire arrangements and similar strategies: Article 12 of the MLI
1.6.2. Artificial avoidance of permanent establishment status through the specific activity exemptions: Article 13 of the MLI
1.6.3. Splitting-up of contracts: Article 14 of the MLI
1.6.4. Definition of a person closely related to an enterprise: Article 15 of the MLI
1.7. Improving dispute resolution, arbitration, corresponding adjustments
1.7.1. MAP improvement
1.7.2. Arbitration
1.7.3. Corresponding adjustments
1.8. General policy on options and reservations
1.9. Constitutional issues
1.9.1. Adoption procedures
1.9.2. Subsequent withdrawal or entry of other countries to the MLI.
1.9.3. Subsequent withdrawal of reservations
1.9.4. Consolidated versions of treaties
1.9.5. Language issues
1.9.6. Conference of the parties
1.10. Overall evaluation and future outlook
Part Two
Chapter 2: Implementing the Multilateral Instrument in Argentina
2.1. Party to the MLI and Covered Tax Agreements
2.1.1. Party to the MLI
2.1.2. Covered Tax Agreements
2.2. Hybrid mismatches
2.2.1. Transparent entities: Article 3 of the MLI
2.2.2. Dual-resident companies: Article 4 of the MLI
2.2.3. Application of methods for elimination of double taxation: Article 5 of the MLI
2.3. Treaty abuse
2.3.1. Preamble: Article 6 of the MLI
2.3.2. Main purpose test: Article 7 of the MLI
2.3.3. Simplified limitation on benefits: Article 7 of the MLI
2.3.4. Dividend transfer transaction: Article 8 of the MLI
2.3.5. Capital gains from alienation of shares or interests of entities deriving their value principally from immovable property: Article 9 of the MLI
2.3.6. Anti-abuse provision for permanent establishments situated in third jurisdictions: Article 10 of the MLI
2.3.7. Application of tax agreements to restrict a party's right to tax its own residents: Article 11 of the MLI
2.4. Avoidance of permanent establishment status
2.4.1. Artificial avoidance of permanent establishment status through commissionaire arrangements and similar strategies: Article 12 of the MLI
2.4.2. Artificial avoidance of permanent establishment status through the specific activity exemptions: Article 13 of the MLI
2.4.3. Splitting-up of contracts: Article 14 of the MLI
2.4.4. Definition of a person closely related to an enterprise: Article 15 of the MLI
2.5. Improving dispute resolution, arbitration, corresponding adjustments
2.5.1. MAP improvement
2.5.2. Arbitration
2.5.3. Corresponding adjustments.
2.6. General policy on options and reservations
2.7. Constitutional issues
2.7.1. Adoption procedures
2.7.2. Subsequent withdrawal or entry of other countries to the MLI
2.7.3. Subsequent withdrawal of reservations
2.7.4. Consolidated versions of treaties
2.7.5. Language issues
2.7.6. Conference of the parties
2.8. Overall evaluation and future outlook
Chapter 3: Implementing the Multilateral Instrument in Australia
3.1. Party to the MLI and Covered Tax Agreements
3.1.1. Party to the MLI
3.1.2. Covered Tax Agreements
3.2. Hybrid mismatches
3.2.1. Transparent entities: Article 3 of the MLI
3.2.2. Dual-resident companies: Article 4 of the MLI
3.2.3. Application of methods for elimination of double taxation: Article 5 of the MLI
3.3. Treaty abuse
3.3.1. Preamble: Article 6 of the MLI
3.3.2. Main purpose test: Article 7 of the MLI
3.3.3. Simplified limitation on benefits: Article 7 of the MLI
3.3.4. Dividend transfer transaction: Article 8 of the MLI
3.3.5. Capital gains from alienation of shares or interests of entities deriving their value principally from immovable property: Article 9 of the MLI
3.3.6. Anti-abuse provision for permanent establishments situated in third jurisdictions: Article 10 of the MLI
3.3.7. Application of tax agreements to restrict a party's right to tax its own residents: Article 11 of the MLI
3.4. Avoidance of permanent establishment status
3.4.1. Artificial avoidance of permanent establishment status through commissionaire arrangements and similar strategies: Article 12 of the MLI
3.4.2. Artificial avoidance of permanent establishment status through the specific activity exemptions: Article 13 of the MLI
3.4.3. Splitting-up of contracts: Article 14 of the MLI.
3.4.4. Definition of a person closely related to an enterprise: Article 15 of the MLI
3.5. Improving dispute resolution, arbitration, corresponding adjustments
3.5.1. MAP improvement
3.5.2. Arbitration
3.5.3. Corresponding adjustments
3.6. General policy on options and reservations
3.7. Constitutional issues
3.7.1. Adoption procedures
3.7.2. Subsequent withdrawal or entry of other countries to the MLI
3.7.3. Subsequent withdrawal of reservations
3.7.4. Consolidated versions of treaties
3.7.5. Language issues
3.7.6. Conference of the parties
3.8. Overall evaluation and future outlook
Chapter 4: Implementing the Multilateral Instrument in Austria
4.1. Party to the MLI and Covered Tax Agreements
4.1.1. Party to the MLI
4.1.2. Covered Tax Agreements
4.2. Hybrid mismatches
4.2.1. Transparent entities: Article 3 of the MLI
4.2.2. Dual-resident companies: Article 4 of the MLI
4.2.3. Application of methods for elimination of double taxation: Article 5 of the MLI
4.3. Treaty abuse
4.3.1. Preamble: Article 6 of the MLI
4.3.2. Main purpose test: Article 7 of the MLI
4.3.3. Simplified limitation on benefits: Article 7 of the MLI
4.3.4. Dividend transfer transaction: Article 8 of the MLI
4.3.5. Capital gains from alienation of shares or interests of entities deriving their value principally from immovable property: Article 9 of the MLI
4.3.6. Anti-abuse provision for permanent establishments situated in third jurisdictions: Article 10 of the MLI
4.3.7. Application of tax agreements to restrict a party's right to tax its own residents: Article 11 of the MLI
4.4. Avoidance of permanent establishment status
4.4.1. Artificial avoidance of permanent establishment status through commissionaire arrangements and similar strategies: Article 12 of the MLI.
4.4.2. Artificial avoidance of permanent establishment status through specific activity exemptions: Article 13 of the MLI
4.4.3. Splitting-up of contracts: Article 14 of the MLI
4.4.4. Definition of a person closely related to an enterprise: Article 15 of the MLI
4.5. Improving dispute resolution, arbitration, corresponding adjustments
4.5.1. MAP improvement
4.5.2. Arbitration
4.5.3. Corresponding adjustments
4.6. General policy on options and reservations
4.7. Constitutional issues
4.7.1. Adoption procedures
4.7.2. Subsequent withdrawal or entry of other countries to the MLI
4.7.3. Subsequent withdrawal of reservations
4.7.4. Consolidated versions of treaties
4.7.5. Language issues
4.7.6. Conference of the parties
4.8. Overall evaluation and future outlook
Chapter 5: Implementing the Multilateral Instrument in Belgium
5.1. Party to the MLI and Covered Tax Agreements
5.1.1. Party to the MLI
5.1.2. Covered Tax Agreements
5.2. Hybrid mismatches
5.2.1. Transparent entities: Article 3 of the MLI
5.2.2. Dual-resident companies: Article 4 of the MLI
5.2.3. Application of methods for elimination of double taxation: Article 5 of the MLI
5.3. Treaty abuse
5.3.1. Preamble: Article 6 of the MLI
5.3.2. Main purpose test: Article 7 of the MLI
5.3.3. Simplified limitation on benefits: Article 7 of the MLI
5.3.4. Dividend transfer transaction: Article 8 of the MLI
5.3.5. Capital gains from alienation of shares or interests of entities deriving their value principally from real property: Article 9 of the MLI
5.3.6. Anti-abuse provision for permanent establishments situated in third jurisdictions: Article 10 of the MLI
5.3.7. Application of tax agreements to restrict a party's right to tax its own residents: Article 11 of the MLI.
5.4. Avoidance of permanent establishment status.
Title
Copyright
Preface
Part One
Chapter 1: The Implementation and Lasting Effects of the Multilateral Instrument: General Report
1.1. Party to the MLI
1.2. Covered Tax Agreements
1.3. Hybrid mismatches
1.3.1. Transparent entities: Article 3 of the MLI
1.3.2. Dual-resident companies: Article 4 of the MLI
1.4. Application of methods for elimination of double taxation: Article 5 of the MLI
1.5. Treaty abuse
1.5.1. Preamble: Article 6 of the MLI
1.5.2. Main purpose test: Article 7 of the MLI
1.5.3. Simplified limitation on benefits: Article 7 of the MLI
1.5.4. Dividend transfer transaction: Article 8 of the MLI
1.5.5. Capital gains from alienation of shares or interests of entities deriving their value principally from immovable property: Article 9 of the MLI
1.5.6. Anti-abuse provision for permanent establishments situated in third jurisdictions: Article 10 of the MLI
1.5.7. Application of tax agreements to restrict a party's right to tax its own residents: Article 11 of the MLI
1.6. Avoidance of permanent establishment status
1.6.1. Artificial avoidance of permanent establishment status through commissionaire arrangements and similar strategies: Article 12 of the MLI
1.6.2. Artificial avoidance of permanent establishment status through the specific activity exemptions: Article 13 of the MLI
1.6.3. Splitting-up of contracts: Article 14 of the MLI
1.6.4. Definition of a person closely related to an enterprise: Article 15 of the MLI
1.7. Improving dispute resolution, arbitration, corresponding adjustments
1.7.1. MAP improvement
1.7.2. Arbitration
1.7.3. Corresponding adjustments
1.8. General policy on options and reservations
1.9. Constitutional issues
1.9.1. Adoption procedures
1.9.2. Subsequent withdrawal or entry of other countries to the MLI.
1.9.3. Subsequent withdrawal of reservations
1.9.4. Consolidated versions of treaties
1.9.5. Language issues
1.9.6. Conference of the parties
1.10. Overall evaluation and future outlook
Part Two
Chapter 2: Implementing the Multilateral Instrument in Argentina
2.1. Party to the MLI and Covered Tax Agreements
2.1.1. Party to the MLI
2.1.2. Covered Tax Agreements
2.2. Hybrid mismatches
2.2.1. Transparent entities: Article 3 of the MLI
2.2.2. Dual-resident companies: Article 4 of the MLI
2.2.3. Application of methods for elimination of double taxation: Article 5 of the MLI
2.3. Treaty abuse
2.3.1. Preamble: Article 6 of the MLI
2.3.2. Main purpose test: Article 7 of the MLI
2.3.3. Simplified limitation on benefits: Article 7 of the MLI
2.3.4. Dividend transfer transaction: Article 8 of the MLI
2.3.5. Capital gains from alienation of shares or interests of entities deriving their value principally from immovable property: Article 9 of the MLI
2.3.6. Anti-abuse provision for permanent establishments situated in third jurisdictions: Article 10 of the MLI
2.3.7. Application of tax agreements to restrict a party's right to tax its own residents: Article 11 of the MLI
2.4. Avoidance of permanent establishment status
2.4.1. Artificial avoidance of permanent establishment status through commissionaire arrangements and similar strategies: Article 12 of the MLI
2.4.2. Artificial avoidance of permanent establishment status through the specific activity exemptions: Article 13 of the MLI
2.4.3. Splitting-up of contracts: Article 14 of the MLI
2.4.4. Definition of a person closely related to an enterprise: Article 15 of the MLI
2.5. Improving dispute resolution, arbitration, corresponding adjustments
2.5.1. MAP improvement
2.5.2. Arbitration
2.5.3. Corresponding adjustments.
2.6. General policy on options and reservations
2.7. Constitutional issues
2.7.1. Adoption procedures
2.7.2. Subsequent withdrawal or entry of other countries to the MLI
2.7.3. Subsequent withdrawal of reservations
2.7.4. Consolidated versions of treaties
2.7.5. Language issues
2.7.6. Conference of the parties
2.8. Overall evaluation and future outlook
Chapter 3: Implementing the Multilateral Instrument in Australia
3.1. Party to the MLI and Covered Tax Agreements
3.1.1. Party to the MLI
3.1.2. Covered Tax Agreements
3.2. Hybrid mismatches
3.2.1. Transparent entities: Article 3 of the MLI
3.2.2. Dual-resident companies: Article 4 of the MLI
3.2.3. Application of methods for elimination of double taxation: Article 5 of the MLI
3.3. Treaty abuse
3.3.1. Preamble: Article 6 of the MLI
3.3.2. Main purpose test: Article 7 of the MLI
3.3.3. Simplified limitation on benefits: Article 7 of the MLI
3.3.4. Dividend transfer transaction: Article 8 of the MLI
3.3.5. Capital gains from alienation of shares or interests of entities deriving their value principally from immovable property: Article 9 of the MLI
3.3.6. Anti-abuse provision for permanent establishments situated in third jurisdictions: Article 10 of the MLI
3.3.7. Application of tax agreements to restrict a party's right to tax its own residents: Article 11 of the MLI
3.4. Avoidance of permanent establishment status
3.4.1. Artificial avoidance of permanent establishment status through commissionaire arrangements and similar strategies: Article 12 of the MLI
3.4.2. Artificial avoidance of permanent establishment status through the specific activity exemptions: Article 13 of the MLI
3.4.3. Splitting-up of contracts: Article 14 of the MLI.
3.4.4. Definition of a person closely related to an enterprise: Article 15 of the MLI
3.5. Improving dispute resolution, arbitration, corresponding adjustments
3.5.1. MAP improvement
3.5.2. Arbitration
3.5.3. Corresponding adjustments
3.6. General policy on options and reservations
3.7. Constitutional issues
3.7.1. Adoption procedures
3.7.2. Subsequent withdrawal or entry of other countries to the MLI
3.7.3. Subsequent withdrawal of reservations
3.7.4. Consolidated versions of treaties
3.7.5. Language issues
3.7.6. Conference of the parties
3.8. Overall evaluation and future outlook
Chapter 4: Implementing the Multilateral Instrument in Austria
4.1. Party to the MLI and Covered Tax Agreements
4.1.1. Party to the MLI
4.1.2. Covered Tax Agreements
4.2. Hybrid mismatches
4.2.1. Transparent entities: Article 3 of the MLI
4.2.2. Dual-resident companies: Article 4 of the MLI
4.2.3. Application of methods for elimination of double taxation: Article 5 of the MLI
4.3. Treaty abuse
4.3.1. Preamble: Article 6 of the MLI
4.3.2. Main purpose test: Article 7 of the MLI
4.3.3. Simplified limitation on benefits: Article 7 of the MLI
4.3.4. Dividend transfer transaction: Article 8 of the MLI
4.3.5. Capital gains from alienation of shares or interests of entities deriving their value principally from immovable property: Article 9 of the MLI
4.3.6. Anti-abuse provision for permanent establishments situated in third jurisdictions: Article 10 of the MLI
4.3.7. Application of tax agreements to restrict a party's right to tax its own residents: Article 11 of the MLI
4.4. Avoidance of permanent establishment status
4.4.1. Artificial avoidance of permanent establishment status through commissionaire arrangements and similar strategies: Article 12 of the MLI.
4.4.2. Artificial avoidance of permanent establishment status through specific activity exemptions: Article 13 of the MLI
4.4.3. Splitting-up of contracts: Article 14 of the MLI
4.4.4. Definition of a person closely related to an enterprise: Article 15 of the MLI
4.5. Improving dispute resolution, arbitration, corresponding adjustments
4.5.1. MAP improvement
4.5.2. Arbitration
4.5.3. Corresponding adjustments
4.6. General policy on options and reservations
4.7. Constitutional issues
4.7.1. Adoption procedures
4.7.2. Subsequent withdrawal or entry of other countries to the MLI
4.7.3. Subsequent withdrawal of reservations
4.7.4. Consolidated versions of treaties
4.7.5. Language issues
4.7.6. Conference of the parties
4.8. Overall evaluation and future outlook
Chapter 5: Implementing the Multilateral Instrument in Belgium
5.1. Party to the MLI and Covered Tax Agreements
5.1.1. Party to the MLI
5.1.2. Covered Tax Agreements
5.2. Hybrid mismatches
5.2.1. Transparent entities: Article 3 of the MLI
5.2.2. Dual-resident companies: Article 4 of the MLI
5.2.3. Application of methods for elimination of double taxation: Article 5 of the MLI
5.3. Treaty abuse
5.3.1. Preamble: Article 6 of the MLI
5.3.2. Main purpose test: Article 7 of the MLI
5.3.3. Simplified limitation on benefits: Article 7 of the MLI
5.3.4. Dividend transfer transaction: Article 8 of the MLI
5.3.5. Capital gains from alienation of shares or interests of entities deriving their value principally from real property: Article 9 of the MLI
5.3.6. Anti-abuse provision for permanent establishments situated in third jurisdictions: Article 10 of the MLI
5.3.7. Application of tax agreements to restrict a party's right to tax its own residents: Article 11 of the MLI.
5.4. Avoidance of permanent establishment status.