UK and International Tax news

Multilateral Convention On BEPS Update

Friday 2nd February 2018

The OECD has recently announced that a further six jurisdictions have signed up to the Multilateral Convention on BEPS under Action 15 bringing the total number of signatories to 78.

In November 2016, 72 jurisdictions signed or formally expressed their intention to sign the convention that would implement a series of tax treaty measures to update the existing network of bilateral tax treaties and reduce opportunities for tax avoidance by multinational enterprises.

The Convention will transpose results from the OECD/G20 BEPS project in respect of four Actions including Hybrid Mismatches under Action 2, Treaty Abuse under Action 6, Avoidance of Permanent Establishment Status under Action 7 and Improving Dispute Resolution under Action 14 into more than 2,000 tax treaties worldwide.

Ther latest signatories include Barbados, Côte d’Ivoire, Jamaica, Malaysia, Panama and Tunisia.

The OECD has also announced that Algeria, Kazakhstan, Oman and Swaziland have expressed their intent to sign the Convention, and a number of other jurisdictions are actively working towards signature by June 2018. So far, four jurisdictions [Austria, the Isle of Man, Jersey and Poland] have ratified the Convention, which will enter into force three months after a fifth jurisdiction deposits its instrument of ratification.

It is expected that the first modifications to bilateral tax treaties are to enter into effect in early 2018.

The OECD is the depositary of the multilateral convention and is supporting governments in the process of signature, ratification and implementation. The position of each signatory under the convention is now available on the OECD website and the OECD provides a database and additional tools on its website, facilitating the application of the convention by taxpayers and tax administrations.

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