Markus Deutsch - Aktuelles



On 31 May 2016, the OECD opened a public consultation (until 30 June) on creating a multilateral instrument to implement the tax treaty-related BEPS measures by modifying bilateral tax treaties (Action 15 of the BEPS Action Plan). An Ad Hoc Group of now 96 countries charged with developing such legal instrument was set up in May 2015. The Group aims to conclude its work and open the multilateral instrument for signature by the end of this year.


The OECD invites comments specifically on the implementation of the multilateral agreement and on the matters it will deal with, namely a mutual agreement procedure including an optional provision for binding arbitration and provisions on hybrid mismatch arrangements, tax treaty benefits in inappropriate circumstances, and the artificial avoidance of "permanent establishment" status.


The OECD also updated its BEPS timetable: The next consultation papers the OECD is planning to issue are:


-       Design and operation of the group ratio rule for interest deductions: 6 July 2016

                 (deadline: 3 August 2016).

-    Hybrid mismatches and branches: 15 July 2016 (deadline: 28 July 2016).

-    Interest limitation in the banking and insurance sectors: 18 July 2016

                 (deadline: 29 August).  




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