International and EU Tax Multilateralism: Challenges Raised by the MLI

International and EU Tax Multilateralism: Challenges Raised by the MLI
A comprehensive discussion of the meaning of multilateralism in international taxation, as well as the impact of the BEPS Project in the move towards international tax multilateralism.

Why this book?

This book on international tax multilateralism is composed of 11 chapters, which comprehensively discuss the meaning of multilateralism in international taxation from various complementary perspectives, as well as the impact of the base erosion and profit shifting project (BEPS Project) in the move towards international tax multilateralism. The insightful research on the topics now published started in preparation for the 13th GREIT Conference held in Lisbon in 2018.

In order to assess international tax multilateralism, the book focuses on the OECD Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI), the Inclusive Framework, as well as on EU multilateralism.

The reader will find a thorough and ground-breaking analysis on the following subjects: formal versus substantial multilateralism; the features and challenges of the MLI; the obligations of MLI non-signatories within the Inclusive Framework, interpretation of the MLI and implementation issues; whether multilateralism is the purpose of the EU and TFEU Treaties and EU multilateralism, tax good governance, and its development policy; specific MLI regimes; and multilateral dispute resolution mechanisms.

The comprehensive research and complementary angles of analysis published in this volume make for essential reading on the issue. The book is addressed to academics, state, international and EU institutions, and practitioners dealing with the MLI and EU multilateral fiscal policies, and the intricate interpretation challenges they raise.


Sample excerpt, including table of contents

This book is part of the GREIT Series

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Paolo Arginelli, Daniel Blum, Cécile Brokelind, Ana Paula Dourado, Guilherme Galdino, Ricardo García Antón, Sriram Govind, Błażej Kuźniacki, Marcus Livio Gomes, Richard Lyal, Jérôme Monsenego, Rainer Prokisch, Luís Eduardo Schoueri, Fernando Souza de Man, Rita Szudoczky, Frans Vanistendael.

International and EU Tax Multilateralism: Challenges Raised by the MLI
Introduction: International Tax Multilateralism or Reinforced Unilateralism?
Chapter 1: Substantive Multilateralism in the Context of the MLI
Chapter 2: Is There a Role for Multilateralism Regarding the Euro in the EMU?
Chapter 3: The European Union and Tax Good Governance in a Multilateral Environment
Chapter 4: Binding Coordination in the European Union: Status Quo and Ideas for a Brighter Future
Chapter 5: Unveiling the MLI: An Analysis of Its Nature, Relationship to Covered Tax Agreements and Interpretation in Light of the Obligations of Its Parties
Chapter 6: Obligations to MLI Non-Signatories within the Inclusive Framework
Chapter 7: Multilateralism and International Tax Law: The Interpretation of Tax Treaties in Light of the Multilateral Instrument
Chapter 8: The Multilateral Instrument and Asymmetric Choices under Articles 12-15 on PE Threshold
Chapter 9: From the Guiding Principle to the Principal Purpose Test: Burden of Proof and Legal Consequences
Chapter 10: Implementation and Application of the LOB Clause in BEPS Action 6/MLI: Legal and Pragmatic Challenges
Chapter 11: Multilateralism in Dispute Resolution: Some Thoughts on the OECD Multilateral Instrument and the EU Dispute Resolution Directive