EXPLANATORY STATEMENT TO THE MULTILATERAL …

← Back to document page

1 EXPLANATORY STATEMENT TO THE MULTILATERAL CONVENTION TO IMPLEMENT TAX TREATY RELATED MEASURES TO PREVENT BASE EROSION AND PROFIT SHIFTING Background 1. The MULTILATERAL Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (the Convention) is one of the outcomes of the OECD/G20 Project to tackle Base Erosion and Profit Shifting (the BEPS Project ) tax planning strategies that exploit gaps and mismatches in tax rules to artificially shift profits to low or no-tax locations where there is little or no economic activity, resulting in little or no overall corporate tax being paid. 2. The BEPS Action Plan was developed by the OECD Committee on Fiscal Affairs (CFA) and endorsed by the G20 Leaders in September 2013.

Group, and in the SubGroup on Arbitration, to provide - clarification of the approach taken in the Convention and how each provision is intended to affect tax

  Testament, Arbitration, Explanatory, Explanatory statement