The Organisation for Economic Cooperation and Development (OECD) today released a report that provides an overview of changes to tax treaties resulting from application of the multilateral instrument (MLI).
As noted in the OECD release, the MLI currently covers 84 jurisdictions, and beginning 1 January 2019, the MLI will apply for the first 47 tax treaties concluded among the 15 jurisdictions that have deposited their acceptances or ratification instruments.
Today’s OECD report—Guidance for the Development of Synthesised Texts [PDF 1.27 MB] (102 pages)—is intended to present an overview of the modifications to tax treaties resulting from application of the MLI on existing tax treaties.
Separately, the OECD has provided a “Secretariat note” [PDF 51 KB] to clarify the entry into effect rules for tax treaties of jurisdictions that have deposited their ratification instruments as of September 2018.
The OECD noted that several jurisdictions have already started preparing “synthesised texts” by taking into account their own publication requirements and practices. For instance, Poland was the first jurisdiction to publish synthesised texts. The release of today’s guidance is intended to help in the preparation of synthesised texts in a consistent manner.
The KPMG logo and name are trademarks of KPMG International. KPMG International is a Swiss cooperative that serves as a coordinating entity for a network of independent member firms. KPMG International provides no audit or other client services. Such services are provided solely by member firms in their respective geographic areas. KPMG International and its member firms are legally distinct and separate entities. They are not and nothing contained herein shall be construed to place these entities in the relationship of parents, subsidiaries, agents, partners, or joint venturers. No member firm has any authority (actual, apparent, implied or otherwise) to obligate or bind KPMG International or any member firm in any manner whatsoever. The information contained in herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor 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 on such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at: + 1 202 533 4366, 1801 K Street NW, Washington, DC 20006.