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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. It identified 15 actions to address base erosion and profit shifting (BEPS) in a comprehensive manner, and set out deadlines to implement those actions.

7. The ad hoc Group was open to all interested countries participating on an equal footing. 99 countries participated in the ad hoc Group as members.Four nonState jurisdictions and seven - international or regional organisations participated as observers.

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