The OECD BEPS Multilateral Instrument and the Issue of Language

INTERTAX, Volume 47, Issue 6 & 7, 2019

19 Pages Posted: 5 Jun 2020

Date Written: June 1, 2019

Abstract

This Article discusses the OECD BEPS MLI in respect of its policy to implement equally authoritative English and French texts. It evaluates this choice against the background of the policies implemented in the final clauses of all existing bilateral tax treaties, and proposes possible solutions to resolve the problems resulting from the MLI final clause. The global tax treaty network is modeled based on a sample of 3,358 tax treaties currently concluded. Unless otherwise noted, translations are my own.

Keywords: Tax Treaties, Taxation, Authentic Languages, OECD Model, OECD Commentary, BEPS, MLI, Interpretation

JEL Classification: K33, K34

Suggested Citation

Resch, Richard Xenophon, The OECD BEPS Multilateral Instrument and the Issue of Language (June 1, 2019). INTERTAX, Volume 47, Issue 6 & 7, 2019, Available at SSRN: https://ssrn.com/abstract=3596869

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