Multilateral Instrument

Article 4

Finance

14 May 2019 IFA Conference – Stephanie Smith on MLI – MLI Progress

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Locations of other summaries Wordcount
Tax Topics - Treaties - Multilateral Instrument - Article 19 majority of arbitration Articles provide for baseball-style arbitration 57

Article 6

Articles

Michael N. Kandev, "Taxpayer Wins Treaty Shopping Challenge in Alta Energy Luxembourg", Tax Management International Journal, 14 September 2018, p. 572

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Article 6(1)

Articles

David G. Duff, "Tax Treaty Abuse and the Principal Purpose Test – Part 2", Canadian Tax Journal, (2018) 66:4, 947-1011

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Article 7

Articles

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

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Jack Silverson, Bill Corcoran, "Issues Affecting Investments by Canadian Pension Plans in Private Equity, Infrastructure and Real Estate in Canada, the USA and Europe", 2016 Conference Report (Canadian Tax Foundation),15:1-40

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Article 7(1)

Administrative Policy

16 May 2018 IFA Roundtable Q. 2, 2018-0749181C6 - Principal Purpose Test in MLI

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21 November 2017 CTF Roundtable Q. 8, 2017-0724151C6 - Principal Purpose Test

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Finance

14 May 2019 IFA Conference – Stephanie Smith on MLI – GAAR and PPT

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Articles

Michael N. Kandev, John J. Lennard, "Interpreting the Expression 'Arrangement or Transaction' in the Principal Purpose Test of the MLI", International Tax (Wolters Kluwer CCH), June 2019, No. 106, p. 1

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David G. Duff, "Tax Treaty Abuse and the Principal Purpose Test – Part 2", Canadian Tax Journal, (2018) 66:4, 947-1011

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.

Article 7(4)

Articles

David G. Duff, "Tax Treaty Abuse and the Principal Purpose Test – Part 2", Canadian Tax Journal, (2018) 66:4, 947-1011

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Article 8

Article 8(1)

Administrative Policy

27 November 2018 CTF Roundtable Q. 3, 2018-0779891C6 - MLI Issues

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Article 13

Articles

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

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Article 19

Finance

14 May 2019 IFA Conference – Stephanie Smith on MLI – MLI Progress

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Locations of other summaries Wordcount
Tax Topics - Treaties - Multilateral Instrument - Article 4 post MLI, most of Canada’s treaties will have a residence tie-breaker rule 78

Articles

Gerrit Groen, "The Nature and Scope of the Mandatory Arbitration Provision in the OECD Multilateral Convention (2016)", Bulletin for International Taxation, November 2017, p. 607

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Article 20

Articles

Gerrit Groen, "The Nature and Scope of the Mandatory Arbitration Provision in the OECD Multilateral Convention (2016)", Bulletin for International Taxation, November 2017, p. 607

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Article 28

Article 28(2)

Articles

Gerrit Groen, "The Nature and Scope of the Mandatory Arbitration Provision in the OECD Multilateral Convention (2016)", Bulletin for International Taxation, November 2017, p. 607

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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

The text of this content is paywalled Mon.-Fri. except for the 1st full week of each month. Subscribe or log in for unrestricted access.