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07 December 2016

OECD's release of multilateral instrument to implement treaty-related BEPS measures has implications for Sovereign Wealth, Pension and Private Equity Funds

The Organisation for Economic Co-Operation and Development (OECD) on November 24, released the text of a Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (BEPS) under BEPS Action 15, together with a detailed Explanatory Statement (the multilateral instrument or MLI). The MLI exists in order to combat perceived improper base erosion and profit shifting. Sovereign Wealth, Pension and Private Equity Funds may see changes to many bilateral tax treaties that will impact the viability of existing or anticipated holding company structures and regional investment related activities.

A Tax Alert prepared by Ernst & Young Global Compliance and Reporting in New York, and attached below, provides additional details.

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ATTACHMENT

Full text of Tax Alert 2016-2068

Document ID: 2016-2068

 

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