Tax treaty modification: multilateral convention implements BEPS measures to prevent treaty abuse and align covered agreements. This instrument implements a multilateral convention to modify Covered Tax Agreements to address Base Erosion and Profit Shifting by targeting treaty-shopping, hybrid mismatch arrangements, artificial avoidance of permanent establishment status, and improving dispute resolution, giving effect to those modifications in the territory in accordance with the State's declared positions and reservations.
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Provisions expressly mentioned in the judgment/order text.
Tax treaty modification: multilateral convention implements BEPS measures to prevent treaty abuse and align covered agreements.
This instrument implements a multilateral convention to modify Covered Tax Agreements to address Base Erosion and Profit Shifting by targeting treaty-shopping, hybrid mismatch arrangements, artificial avoidance of permanent establishment status, and improving dispute resolution, giving effect to those modifications in the territory in accordance with the State's declared positions and reservations.
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