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By Alfred Chan
Article 35(4) provides that Article 16 (MAP) shall have effect with respect to a CTA for a case presented to the competent authority of a contracting jurisdiction on or after the latest of the dates on which the MLI ...
By Alfred Chan
The Multilateral Convention to Implement Tax Related Measures to Prevent Base Erosion and Profit Shifting (the multilateral Instrument, the MLI), developed by the OECD and endorsed by the G20, offers concrete solutions ...
By Alfred Chan
In negotiating a tax treaty, both parties can discuss and cover every topic and insert it in the agreement or protocol.
By Alfred Chan
Note that this section illustrates how Article 16 works in practice from an Australian perspective.
By Alfred Chan
The following is Part 3 of the above captioned article that specifically deals with How contracting jurisdictions apply Article 16 to their CTA's.
By Alfred Chan
This paper will focus on Article 16 - mutual agreement procedure (the MAP) and will be organized in the following way:
By Alfred Chan
As the following table shows, a Signatory or Party to the Convention can choose to apply paragraph 4 either in addition to or to the exclusion of paragraph 1.
By Alfred Chan
Both Japan and Zealand opts in for Article 9(4), and both of the two contracting states have made notification to the Depositary, pursuant to Article 9(8) of the MLI.
By Alfred Chan
In Section IV, the article ends with a conclusion that one can learn from understanding the MLI as an international convention.
By Alfred Chan
It is observed that except for India, 4 other contracting parties have chosen to opt-in for Article 7(4).
By Alfred Chan
Article 6(1) sets the minimum standard for all Parties that have committed themselves to the OECD/G20 BEPS package.