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Multilateral Instrument Analysis

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Webinars, International Tax, Multilateral Instrument Analysis

MLI Comparative Analysis

Objectives & Agenda :
The Multilateral Instrument (MLI) is the latest development in International taxation which would modify the existing bilateral treaties (DTAAs) and implement measures to prevent Base Erosion Profit Shifting (BEPS) strategies. MLI is a flexible instrument which will modify tax treaties according to a jurisdiction’s policy preferences by providing Alternate provisions, optional provisions and right for reservation. In this webinar, we will analyse the MLI Positions of India and 3 other countries and understand the effect of MLI on the tax treaties between the Countries. The 3 countries considered for analysis in this Webinar are Japan, Singapore and the United Kingdom (UK).

Webinars, International Tax, Multilateral Instrument Analysis

Multilateral Instrument (MLI) – Final Provisions [Articles 27-39]

Objectives & Agenda :
The Multilateral Instrument (MLI) is the latest development in International taxation which would modify the existing bilateral treaties (DTAAs) and implement measures to prevent Base Erosion Profit Shifting (BEPS) strategies. In this Webinar we shall analyse the provisions of Part VII of the MLI containing the Final Provisions covering Articles 27 to 39 Part VII – Final Provisions – Contains provisions governing Functioning of MLI, Effective dates, Reservations, Notifications, Interpretation and Amendments.

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Webinars, International Tax, Multilateral Instrument Analysis

Multilateral Instrument (MLI) – Arbitration [Articles 18-26]

Objectives & Agenda :
The Multilateral Instrument (MLI) is the latest development in International taxation which would modify the existing bilateral treaties (DTAAs) and implement measures to prevent Base Erosion Profit Shifting (BEPS) strategies. In this Webinar we shall analyse the provisions of Part VI of the MLI relating to ‘Arbitration’ which covers Articles 18 to 26. Part VI – Arbitration – Contains provisions which provide for Arbitration in situations where cases submitted by a taxpayer under Mutual Agreement Procedure [MAP], remains unresolved for a long period of time. Part VI also contains provisions with requirements and guidelines for Arbitrators and the Arbitration Procedure.

Webinars, International Tax, Multilateral Instrument Analysis

Multilateral Instrument (MLI) – Treaty Abuse [Articles 6-11]

Objectives & Agenda :
The Multilateral Instrument (MLI) is the latest development in International taxation which would modify the existing bilateral treaties (DTAAs) and implement measures to prevent Base Erosion Profit Shifting (BEPS) strategies. In this Webinar we shall analyse the provisions of Part III of the MLI relating to ‘Treaty Abuse’. Articles 6 to 11 are covered under this Part and provide important concepts like Principle Purpose Test (PPT), Limitation on Benefits (LOB) and anti-abuse measures addressing ‘Triangular PE’ and other treaty-related measures.

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