Multilateral Instrument

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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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(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

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.