The Central Government has ratified the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting(MLI).
The Multilateral Convention is an outcome of the OECD and G20 Project to tackle Base Erosion and Profit Shifting(BEPS Project).
The BEPS Project objective is to tackle base erosion and profit shifting where companies shift their profits to other tax jurisdictions which usually have lower rates,thereby eroding the tax base in India.
The BEPS Project identified 15 actions to address base erosion and profit shifting (BEPS) in a comprehensive manner.
The Convention enables countries to implement the tax treaty related changes to achieve anti-abuse BEPS outcomes through the multilateral route without the need to bilaterally re-negotiate each such agreement which is burdensome and time consuming.
The Convention will modify India’s treaties in order to curb revenue loss through treaty abuse and base erosion and profit shifting strategies by ensuring that profits are taxed where substantive economic activities generating the profits are carried out and where value is created.
Further,the US is not a signatory of this Multilateral Convention as it believes that it has a robust tax treaty network that prevents treaty abuse.
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