OECD guidance for the development of synthesised texts for interpretation of modified treaties
The OECD has released new Guidance for the Development of Synthesised Texts presenting a clear overview of the modifications to tax treaties resulting from the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (the “Convention” or “MLI”) which came into force from 1 July 2018.
A Secretariat note has also been released which clarifies the coming into effect of rules for tax treaties of jurisdictions that deposited their ratification instruments last September.
The Guidance has been developed by the OECD Secretariat with inputs from the members of the Ad hoc Group on the MLI. It can be used by governments that intend to provide insight into the impact of the Convention on existing treaties. Synthesised Texts also provide comprehensive information to taxpayers, auditors, advisors and other users as to when the modifications will have effect in each jurisdiction.
Source : Economic Times