Latest Documents

Multilateral Convention to Facilitate the Implementation of the Pillar Two Subject to Tax Rule

The Global anti-Base Erosion Rules and the Subject to Tax Rule (STTR) are key components of Pillar Two and ensure multinational enterprises pay a minimum level of tax on income arising in each of the jurisdictions where they operate. The treaty-based rule protecting the right of developing Inclusive Framework members to tax certain intra-group payments, where these are subject to nominal corporate income tax below the minimum rate.

Eswatini signs landmark agreement to strengthen its tax treaties and Armenia and Côte d'Ivoire deposit their instrument for the ratification of the Multilateral BEPS Convention

Today, Eswatini signed the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting, at a signing ceremony held in Paris.

Papua New Guinea deposits its instrument for the ratification of key multilateral conventions against tax evasion and avoidance and Romania completes its internal procedures for the entry into effect of the provisions of the Multilateral BEPS Convention

On 31 August 2023, Papua New Guinea deposited its instrument of ratification for the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (BEPS Convention) as well as the Multilateral Convention on Mutual Administrative Assistance in Tax Matters.

Tunisia deposits its instrument for the ratification of the Multilateral BEPS Convention

On 24 July, Tunisia deposited its instrument of ratification for the Multilateral BEPS Convention, which now covers around 1 850 bilateral tax treaties, underlining its strong commitment to prevent the abuse of tax treaties and base erosion and profit shifting by multinational enterprises.

OECD launches new version of the BEPS Multilateral Convention Matching Database to further support international tax co-operation

A new and improved version of the database supporting the application of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (the "BEPS MLI") has been released and will allow tax authorities and other interested parties to make projections on how the MLI modifies a specific tax treaty.

BEPS MLI Matching Database

An updated version of the database supporting the BEPS MLI application has been released, enabling tax authorities and others to project how the MLI modifies specific tax treaties. First published in 2017, this updated database is a vital tool for stakeholders implementing the BEPS MLI. It offers current and detailed information on the MLI's application to tax treaties, including "matching results" for each covered treaty.

Viet Nam deposits its instrument for the ratification of the Multilateral BEPS Convention

Vietnam ratifies BEPS Convention, now covering around 1850 bilateral tax treaties, showing commitment against abuse of tax treaties and BEPS by multinational enterprises. Effective from 1 September 2023.

Sustained progress demonstrated in the latest OECD peer review results on the prevention of tax treaty shopping

These peer review results reveal that members of the Inclusive Framework on BEPS are respecting their commitment to implement the minimum standard on treaty shopping and further confirms the importance of the BEPS Multilateral Instrument (MLI) as the tool used by the vast majority of jurisdictions that have started to implement the BEPS Action 6 minimum standard.

Prevention of Tax Treaty Abuse – Fifth Peer Review Report on Treaty Shopping - Inclusive Framework on BEPS: Action 6

Mexico deposita su instrumento de ratificación de la Convención Multilateral de BEPS

Mexico ha depositado su instrumento de ratificación de la Convención Multilateral que implementa las medidas relacionadas a convenios tributarios para prevenir la erosión de la base imponible y el desvío de beneficios con lo cual acentúa su fuerte compromiso para prevenir el abuso de los convenios tributarios, la erosión de la base imponible y el desvío de beneficios por parte de empresas multinacionales.