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A Multilateral Convention for Tax: From Theory to Implementation

A Multilateral Convention for Tax: From Theory to Implementation

SKU:10059364-0002
Sergio André Rocha, Allison Christians
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Price:
$169.00
Product Line
Kluwer Law International
Product SKU
10059364-0002
ISBN-13
9789041194282
Availability
Ships in 5-7 Business Days
Last Updated
2021-12-07

Overview

Series on International Taxation Volume 80


A Multilateral Convention for Tax is a pioneering book that assesses a pivotal and revolutionary paradigm shift in the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) versus a mechanism that primarily continues an ongoing flow of limited policy coordination—two radically opposed viewpoints on the convention—with thorough analyses that kindle the hopes and the realities of the current era of multilateral tax cooperation. Since the advent of modern income taxation over a century ago, the MLI has been the most dynamic multilateral initiative coordinating tax regimes on a global basis.


What’s in this book:


Uniting the efforts of authors from national jurisdictions worldwide to scrutinize the MLI and its likely future ramifications, the book furnishes an in-depth commentary and analysis in the following sequence:

  • first, a comprehensive discussion of the design and goals of the MLI as a treaty and an institutional framework;
  • second, an overview of the structure of the convention and its take-up across the globe to date; and
  • third, the substantive implementation of the MLI with a wide range of country reports.


Practice areas covered include tax law, international law, and international relations.


How this will help you:


The legal workings and implications of the MLI might still seem like a mystery to those whose day-to-day work is impacted by it, and as yet, little jurisprudence regarding its legal nature or ultimate effect on the bilateral treaties is coming within its scope. Consequently, this trailblazing book will be highly appreciated by in-house counsel and law firms advising cross-border investors and firms; nongovernmental organizations involved in policy analysis and issue advocacy; researchers working on technical areas of international tax law; and lawyers interested in international policymaking, including the creation and diffusion of consensus-based fiscal and related regulatory norms across jurisdictions of different development levels.

Table Of Contents

Editors


Contributors


Introduction

Allison Christians


PART I

The Purpose, Nature, and Significance of the MLI


CHAPTER 1

Multilateralism, Multilateralism, Who Is Sovereign after All? Tax Sovereignty after BEPS Multilateral Instrument

Rita Calçada Pires


CHAPTER 2

The Multilateral Convention from a Public International Law Perspective

Vanessa Arruda Ferreira


CHAPTER 3

Is the Multilateral Instrument Really Multilateral?

Nathalie Bravo


CHAPTER 4

Risk Society and International Tax Multilateralism

Sergio André Rocha


PART II

Structure and Adoption


CHAPTER 5

The Framework of the Multilateral Instrument

Ramon Tomazela Santos


CHAPTER 6

MLI Implementation and Impact from the Latin American Perspective

Andrea Laura Riccardi Sacchi


CHAPTER 7

A Cross-Jurisdictional Analysis of MLI Implementation to Date

Natalia Pushkareva


PART III

Implementation in Practice: Precedents, Challenges, and Prospects for Uniformity


CHAPTER 8

Domestic and Treaty-Based GAAR and SAAR: Potential Conflicts and Ordering Principles MLI and Argentine Treaty and Domestic Law

Guillermo O. Teijeiro


CHAPTER 9

The DNA of the Principal Purpose Test in the Multilateral Instrument

Marcus Livio Gomes


CHAPTER 10

Virtual PE Concept and the Challenges of a Multilateral Solution

Michell Przepiorka & Gisele Barra Bossa


CHAPTER 11

From Bilateralism to Multilateralism: Is This Shift Beneficial for Developing Countries? A Focus on 7(1) MLI

Ricardo García Antón


CHAPTER 12

Aggressive Tax Planning and Its Interaction with the MLI

Cristián Billardi


Index

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A Multilateral Convention for Tax: From Theory to Implementation | Wolters Kluwer Legal & Regulatory