The Republic of Cyprus was amongst more than 100 jurisdictions present at the OECD Multilateral Convention,for negotiations to implement tax treaty related measures to prevent base erosion and profit shifting, held on 24 November 2016.
Base erosion and profit shifting (BEPS),has become a pressing issue,and the measures introduced are in recognition of the importance of ensuring that profits are taxed where substantive economic activities of the profits are carried out.
Further to our earlier article on the OECD’s proposals for global reforms, the measures devised under the OECD/G20 BEPS project,include tax treaty-related measures for tax avoidance and to prevent treaty abuse and improve dispute resolution.
According OECD’s release, the “Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS” includes:
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- Provisions intended to tackle tax avoidance and the effects of hybrid mismatch arrangements according to Action 2 of the BEPS project
- Provisions addressing treaty benefits granted for inappropriate circumstances under BEPS Action 6
- Revised definition of “permanent establishment” as recommended under BEPS Action 7
- Changes to facilitate access to and resolution of mutual agreement procedures more effective and in line with BEPS Action 14 (including a mandatory binding arbitration provision similar to that of the U.S. tax treaties)
As William Morris, chair of the tax section of the OECD Business and Industry Advisory Committee conveyed, in his 25 November 2016 statement, “We hope that widespread adoption of the multilateral instrument (MLI), will result in a number of the key BEPS recommendations being implemented in a consistent and coordinated way across many countries, so that tax treaties can continue to perform their fundamental role of preventing double taxation and facilitating the cross-border trade and investment that creates inclusive growth, jobs, and wealth for all.”
The Cyprus Ministry of Finance announced in their press release on 5 April 2017, its intention to sign the Multilateral Instrument at the signing ceremony to be held in Paris, in June 2017.