000			01943nab a2200229 c 4500
999			_c145856 _d145856
003			ES-MaIEF
005			20220825135116.0
007			ta
008			220511t2021 ne ||||| |||| 00| 0|eng d
040			_aES-MaIEF _bspa _cES-MaIEF
100			_960616 _aSchoueri, Luís Eduardo
245		4	_aThe influence of the BEPS Multilateral Instrument on tax treaties concluded by non-signatory countries _c Luís Eduardo Schoueri & Ramon Tomazela
500			_aResumen.
520			_aThis article intends to assess the impact of the Base Erosion and Profit Shifting Project (BEPS) Multilateral Instrument (MLI) on tax treaties concluded by non-signatory jurisdictions. To achieve this goal, the authors initiated the analysis with forty-four countries that are members the BEPS Inclusive Framework but have not yet signed the MLI. Out of these forty-four countries, the authors focused on those that had tax treaties signed or amended after 2017 which has narrowed down the scope to the following countries: Angola, Botswana, Brazil, Cape Verde, Congo, Maldives, Thailand, and Vietnam. In this context, the article examines the tax treaty-related BEPS measures that were adopted by these countries in their bilateral tax treaties, addressing the merits and potential consequences of the choices made by non-signatory jurisdictions. Based on the findings of the research, the article concludes that the impact of the MLI varies significantly depending on the tax treaty policy of each country and that, thus far, it has been limited primarily to the minimum standards on dispute resolution.
650		4	_967061 _aCONVENIO MULTILATERAL
650		4	_aFISCALIDAD INTERNACIONAL _944303
650		4	_aTRATADOS INTERNACIONALES _948608
650		4	_aPAÍSES NO SIGNATARIOS _969761
700			_962684 _aSantos, Ramon Tomazela
773	0		_9167169 _oOP 2141/2021/10 _tIntertax _w(IEF)55619 _x 0165-2826 _g v. 49, issue 10, October 2021, p. 818-843
942			_cART