The Organisation for Economic Cooperation and Development (OECD) issued a release that includes a request for public comments with respect to technical issues related to the development of a multilateral instrument to implement the tax-treaty related base erosion and profit shifting (BEPS) measures.
As explained in the OECD release, the report for BEPS Action 15 (Developing a multilateral instrument to modify bilateral tax treaties) concludes that a multilateral instrument to modify bilateral tax treaties for purposes of implementing the tax treaty-related BEPS measures is feasible and desirable. Accordingly, an “ad hoc group” was established in May 2015, and tasked with developing a multilateral instrument to modify existing bilateral tax treaties to allow for swift implementation of the tax treaty measures developed in the course of the OECD-G20 BEPS Project. The ad hoc group (that includes representatives from 96 countries and certain other observers) aims to conclude its work and open the multilateral instrument for signature by 31 December 2016.
The “request for input” outlines the background and purpose of the multilateral instrument and describes briefly the technical issues arising from its development, including issues to be considered in the context of the optional provision on MAP arbitration. Comments are invited with respect to specific questions included in the “request for input,” as well as other technical issues that may arise from implementing the treaty-related BEPS measures in the context of the network of existing bilateral tax treaties. Comments and input are due by 30 June 2016.
The KPMG logo and name are trademarks of KPMG International. KPMG International is a Swiss cooperative that serves as a coordinating entity for a network of independent member firms. KPMG International provides no audit or other client services. Such services are provided solely by member firms in their respective geographic areas. KPMG International and its member firms are legally distinct and separate entities. They are not and nothing contained herein shall be construed to place these entities in the relationship of parents, subsidiaries, agents, partners, or joint venturers. No member firm has any authority (actual, apparent, implied or otherwise) to obligate or bind KPMG International or any member firm in any manner whatsoever. The information contained in herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at: + 1 202 533 4366, 1801 K Street NW, Washington, DC 20006.