On 13 June, KPMG Global hosted a client webinar to discuss the OECD’s multilateral instrument.
Following last week’s signing of the multilateral instrument (MLI), further information and resources from KPMG Global are now available to help companies understand the potential impact for their business. This includes copies of the slides and the playback recording from a webinar held on 13 June 2017, and a KPMG Global Tax News Flash which examines the MLI in more detail and has links to various OECD and local KPMG firm alerts.
As reported in last week’s Tax Matters Digest, on 7 June 2017 representatives from 68 countries and jurisdictions signed the OECD’s MLI introduced as part of its base erosion and profit shifting (BEPS) project. The purpose of the MLI is to implement a number of tax treaty measures included in the BEPS recommendations in relation to treaty abuse, permanent establishments, dispute resolution and hybrid mismatches. In addition to the representatives from the 68 countries, a further 8 signalled their intention to sign. For the countries that have currently signed up, the combined effect of these will be to amend around 1,100 bilateral tax treaties once the MLI takes effect.
Given the range of areas of tax that the MLI covers and the large number of signatories, the MLI represents a significant change in the tax landscape for many companies and especially those with cross border activity. At the very least, the changes to treaties which will arise as a result of the MLI will change the approach that companies need to take in assessing the availability of treaty relief, and as such is likely to increase process and administration especially in the early years of implementation. Other companies may wish to review their legal, financing and operational structures in light of the MLI to proactively manage the impact.
In order to explain the impacts further, KPMG Global held a client webinar on 13 June 2017. A copy of the slides and the playback recording are available here. The webcast set out details of the MLI in overview, including the mechanics of operation, and then went on to explore the impact on a region by region basis. In Europe this included a specific focus on the UK, Ireland, the Netherlands, Germany and Switzerland.
In addition to the webcast, KPMG Global have also published a Global Tax News Flash. This provides a more detailed explanation of the MLI and includes a number of links to both OECD documents and the Tax News Flash alerts from local KPMG offices.
If you have any questions about the MLI, including its potential impact on your business, please get in touch with your usual KPMG contact or a member of the International Tax team listed in this article.
We are in the process of developing additional content relating to the implementation of the MLI including a tracker which, if appropriate, your KPMG team can use to help you navigate the implementation of the MLI and its potential impact on your specific fact pattern.
For further information please contact: