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Global Tax Alert: OECD releases multilateral instrument under BEPS Action 15

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Executive summary

On 24 November 2016, the Organisation for Economic Co-operation and Development (OECD) released the text of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (BEPS) under BEPS Action 15 (the multilateral instrument). The text and the related explanatory statement were formally adopted by approximately 100 countries at a ceremony hosted by the OECD following the conclusion of the negotiations during the week of 21 November 2016.

The text of the multilateral instrument and explanatory notes are available on the OECD website. The multilateral instrument under BEPS Action 15 is a key part of the OECD’s effort toward implementation of the tax treaty related BEPS measures into existing bilateral or regional tax treaties as quickly and consistently as possible.

In general, the multilateral instrument will only enter into force after five countries have ratified it and will apply for a specific tax treaty, after all parties to that treaty have ratified the instrument; and a certain period has passed to ensure clarity and legal certainty. It is expected that the multilateral instrument will be open for signature as of 31 December 2016 and a first high-level signing ceremony will take place in the week beginning 5 June 2017.

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John Hannigan

Aviation Finance, Sector Leader
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