Canada has signed the Multilateral Instrument.
Now that Canada is a signatory, Canadian multinationals could be impacted by changes to tax treaties that may affect their organization's global structure and operations in the future. The Multilateral Instrument was developed as part of Action 15 of the OECD's Base Erosion and Profit Shifting (BEPS) initiative.
The Instrument was signed by 68 countries at a ceremony held on June 7, 2017 in Paris, France. Additional countries intend to sign, including eight who indicated their interest to do so at the time of the ceremony.
Countries signing onto the Multilateral Instrument include the UK, most European countries including Switzerland, Luxembourg and the Netherlands, and a number of Asian countries, including Singapore, China and Hong Kong. Some countries, such as Brazil, were notably absent but had previously intended to sign. Thus, we could see many more than the 100-plus countries who participated in the process signing-on before the end of the year. Of the countries that signed on June 7th, most of their treaties were listed, resulting in the Multilateral Instrument impacting over 1,100 bilateral treaties through matching agreements.
To learn more, see TaxNewsFlash-Canada 2017-33, "Canada Signs on for BEPS Treaty Changes", or speak to your KPMG advisor.
To learn more about the international perspective on the signing, see KPMG Global's report, "KPMG analysis: Multilateral instrument implementing the treaty-related BEPS provisions".
You can also visit the OECD's website to find a list of all the countries that have signed the instrument, as well as their option choices under the Multilateral Instrument.
For more information, contact your KPMG adviser.
Information is current to June 13, 2017. The information contained in this publication is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavour to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act upon such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact KPMG's National Tax Centre at 416.777.8500