THE OECD releases new Guidance for the development of synthesized 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 & profit shifting, which came into force on July 01, 2018. In pursuance thereto, a clarificatory note has also been issued in addendum, simplifying 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. Synthesized Texts also provide comprehensive information to taxpayers, auditors, advisors and other users on when the modifications would have effect in each jurisdiction. Several jurisdictions have already started preparing Synthesized 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 Synthesized Texts on its website. The OECD is also expanding the functionality of the database to include information on entry into effect. The new tools would be presented during a Q&A Webcast on the MLI scheduled for December. |