Brauner, Yariv
McBEPS the MLI : the first Multilateral Tax Treaty that has never been / Yariv Brauner .-- , 2018
The article argues that the multilateral instrument (MLI) was primarily devised to preserve the conservative evolution of the international tax regime, based on bilateral tax treaties, reciprocity and competition, and not as a multilateral tax treaty based on which a new coordinative regime shall arise. The article makes the point, however, that despite this main purpose the mere conclusion of the MLI introduces ambivalence into the international tax regime, breaking with its orthodoxy in a meaningful, even if not yet significant manner. The author makes fifteen observations on the MLI in its current status to substantiate this argument.
EROSIÓN DE LA BASE IMPONIBLE Y TRASLADO DE BENEFICIOS
EVASION FISCAL
ELUSION FISCAL
PREVENCIÓN
PROGRAMAS
APLICACION
CONVENIO MULTILATERAL
TRATADOS INTERNACIONALES
FISCALIDAD INTERNACIONAL
Intertax 0165-2826 v. 46, n. 1, January 2018, 6-17
McBEPS the MLI : the first Multilateral Tax Treaty that has never been / Yariv Brauner .-- , 2018
The article argues that the multilateral instrument (MLI) was primarily devised to preserve the conservative evolution of the international tax regime, based on bilateral tax treaties, reciprocity and competition, and not as a multilateral tax treaty based on which a new coordinative regime shall arise. The article makes the point, however, that despite this main purpose the mere conclusion of the MLI introduces ambivalence into the international tax regime, breaking with its orthodoxy in a meaningful, even if not yet significant manner. The author makes fifteen observations on the MLI in its current status to substantiate this argument.
EROSIÓN DE LA BASE IMPONIBLE Y TRASLADO DE BENEFICIOS
EVASION FISCAL
ELUSION FISCAL
PREVENCIÓN
PROGRAMAS
APLICACION
CONVENIO MULTILATERAL
TRATADOS INTERNACIONALES
FISCALIDAD INTERNACIONAL
Intertax 0165-2826 v. 46, n. 1, January 2018, 6-17