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By Dany TEILLANT, Partner Audrey LEGRAND, Director, Deloitte Luxembourg
1. Concept of the MLI as announced in the BEPS project
As of 6 April 2018, 78 countries(1) signed, and six others(2) announced their intention to sign, the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) that was part of the recommended actions of the BEPS project (Action 15)(3) of the Organization for Economic Co-operation and Development (OECD).
The principal aim of the MLI was to implement the recommendations of BEPS Action 6 on treaty abuse that introduced minimum standards to prevent the granting of double tax agreement (DTA) benefits in unintended...
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