Monitor Podatkowy

no. 5/2017

MULTILATERA L CONVENTION (BEPS NO. 15) – DISCUSSING CORE ISSUES

Michał Leconte
menedżer w Deloitte Doradztwo Podatkowe
Mateusz Raińczuk
starszy konsultant w Deloitte Doradztwo Podatkowe
Abstract

In November 2016 there was a publication of a text on multilateral convention which aim is to implement measures in activities of BEPS regarding contracts on avoiding double taxation (Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profi t Shift ing). Taking eff ect of the Multilateral Convention will simultaneously allow to change multiple contracts on avoiding taxation according to postulates developed within the framework of the BEPS project.Assumedly, it should contribute to reacting against avoiding taxation and make sure that the income is taxed in a place where one actually runs a business to acquire that income.Th e present article aims to show core elements of the Convention and its proposed changes to contracts on avoiding double taxation.