UnscheduledThe BEPS Multilateral Convention and Its Impact on Tax Treaties
- The BEPS Multilateral Convention and Its Impact on Tax Treaties
Overview and Learning Objectives
Following a short general overview of domestic and tax treaty anti-avoidance measures, the first part of this 1.5-day intermediate-level course provides an in-depth analysis of the MLI, particularly its compatibility with the current double tax treaty network (such as the interrelationship between treaties and the MLI, the MLI and the OECD Model/Commentary, and the possible controversies). Procedural provisions (such as scope, structure, entry into force, effective date, chapters and provisions) will be looked at through practical examples before attention will be paid to the substantive rules in the MLI. Two sessions will deal with the provisions on treaty abuse, specifically with the principal purpose test (PPT) and the limitation on benefits (LOB) clause, the two most debated tools in the MLI. Practical implications such as the impact on holding, financing, IP and supply chain structures will be explored. Throughout the course, attention will be given to the different reservations, options and notifications given by major European countries to accentuate the practical impact of the MLI on European corporations.
This is an interactive course with a maximum of 32 participants. Participants will have access to relevant online collections on the IBFD Tax Research Platform for a period of two weeks. Presentations will be made available in electronic format.
Field of Study
Who Should Attend?
The course is suitable for tax practitioners in tax advisory firms, in-house tax personnel and government officials.
Course Level and Prerequisites
This is an intermediate-level course. Participants will be expected to have a good knowledge of the tax treaties, their practical application and impact on structures involving holding, financing and IP companies as well as supply chains.
Interactive course - "Group Live"
To safeguard the interactive nature of the course, including group discussions and case studies, a maximum of 32 participants will be accepted. Early registration is therefore recommended.We invite you to send us in advance any technical, content-related questions you may have. During the course we will try to address your specific questions, but please note that this will depend on the amount of time available, the relevance of the questions and the order in which the questions are received.Should you have a question, please send it to email@example.com.Disclaimer: The information provided during the course has been prepared solely for the instruction of course participants. This information is not intended to constitute advice on any particular matter
Continuing Professional Education
Recommended NASBA CPE points for this course: 12.5 (in accordance with the standards of the National Registry of CPE points, CPE credits are granted based on a 50-minute hour). Read more information on CPE points and accreditation for IBFD International Tax Courses.
Course fee and registration details
The course fee covers participation in the course, all course materials, lunch, coffee/tea and refreshments. The costs of accommodation and transport are not covered. If you have any other questions regarding attendance of the course, travel arrangements, payments and cancellations, please consult our FAQ.
- domestic and Tax Treaty Anti-Avoidance Measures – General Overview
- OECD Multilateral Convention to Implement Measures to Prevent BEPS (MLI)
- MLI – Treaty Abuse, Parts II and III
- MLI – Part IV: The Permanent Establishment, Post-BEPS
- analysis of the General Anti-Avoidance Rule (GAAR) of the Principal Purpose Test (PPT)
- analysis of Limitation on Benefits (LOB) Provisions