آخر تحديث - 14 أكتوبر 2021
The minimum provisions of the standard, in particular the new, stricter abuse test called the Main Objective Test (TPP), must be implemented in all tax treaties. Optional provisions depend on the consent of the Contracting Parties and should not be implemented at all with the consent of the Parties. In many countries, a consolidated version of the amended treaties will not be available. This means that taxpayers applying double taxation treaties will have to consider the MLI and the possible consequences. The key treaty changes that will be implemented by the MLI will be the inclusion of a comprehensive anti-avoidance rule in covered tax treaties, known as the Primary Purpose Test, or TPP. . . .