Manal Corwin, Jesse Eggert, "Understanding the Operation, Impact, and Practical Implications of the MLI", Tax Management International Journal, Vol. 46, No. 8, 11 August 2017, p. 407

Summary Under
Tax Topics - Treaties - Multilateral Instrument - Article 7

Breadth of principal purpose test in MLI, Art. 7(1) compared to existing PPT rules (p. 413)

This expression of the PPT is broader than many...

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Summary Under
Tax Topics - Treaties - Multilateral Instrument - Article 13

Potential uncertainty under existing PE Articles created by MLI Art 13 (p. 414)

MLI Article 13 is intended to address artificial avoidance of PE...

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Summary Under
Tax Topics - Treaties - Multilateral Instrument - Article 28 - Article 28(2)

Vagueness of some free-form reservations to MLI Art. 28 (p. 416)

While the provision applies by default to existing MAP inventories (subject to...

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