UK proposes to change to BEPS MLI reservations and notifications

The UK government today announced proposed changes to the provisional reservations and notifications it made when it signed the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI).

The UK has proposed to omit the treaty with Germany from the list of treaties it intends to modify through the MLI and to add or amend the treatment of treaties with the Faroe Islands, Kyrgyzstan, United Arab Emirates, and Ukraine.

The MLI, developed by the OECD in 2015, is designed to allow countries to swiftly modify their existing bilateral tax treaties to conform the treaties to minimum standards and other agreements reached by nations as a result of the OECD/G20 base erosion profit shifting (BEPS) plan.

The MLI will enter into force for at least five nations on July 1; it was signed by the UK in June 2017 but has not yet been ratified by the UK.

The changes announced today were needed, the government said, to fix errors, list treaties mistakenly omitted, and add treaties signed by the UK since the UK signed the MLI. The treaty with Germany was removed because the two countries decided to implement the BEPS provisions through bilateral agreement instead of through the MLI.

 

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