Explanatory Statement: Multilateral Convention to ...

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.

package, which are the minimum standard for the prevention of treaty abuse under Action 6 and the minimum standard for the improvement of dispute resolution under Action 14. Given, however, that each of those minimum standards can be satisfied in multiple different ways, and given the broad range of

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