Base erosion and profit shifting

OECD releases guidance on Synthesised texts for providing clarity on the impact of the Multilateral Instrument


14/11/2018 - Progress continues on the implementation of a landmark treaty to improve the international tax system which now covers 84 jurisdictions and will become effective on 1 January 2019 for the first 47 tax treaties concluded among the 15 jurisdictions that deposited their acceptance or ratification instrument.


Today the OECD releases new Guidance for the Development of Synthesised Texts presenting a clear overview of the modifications to tax treaties resulting from the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (the "Convention” or “MLI”) which entered into force on 1 July 2018. A Secretariat note, also released today, clarifies the entry into effect rules for tax treaties of jurisdictions that deposited their ratification instruments last September.


The Guidance has been developed by the OECD Secretariat with input from the members of the Ad hoc Group on the MLI. It can be used by governments that intend to provide insight into the impact of the Convention on existing treaties. Synthesised Texts also provide comprehensive information to taxpayers, auditors, advisors and other users on when the modifications will have effect in each jurisdiction.


Several jurisdictions have already started preparing Synthesised Texts on the basis of the Guidance, taking into account their own publication requirements and practices. In September, Poland was the first jurisdiction to publish Synthesised Texts on its website. The release of today’s Guidance intends to ensure that interested parties can prepare synthesised texts in a consistent manner.


The Guidance and the Secretariat Note are the most recent additions to a wide range of existing tools and background documents, including the popular MLI Matching Database. The OECD is also expanding the functionality of the database to include information on entry into effect.


The new tools will be presented during a Q&A Webcast on the MLI scheduled for December. Information on timing and registration will be made available in due course.


Journalists wishing to obtain further information are invited to contact Pascal Saint-Amans, Director of the Centre for Tax Policy and Administration (CTP) or the CTP Communications team.


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