Multilateral Convention on the plan for BEPS

The project of the Organisation for Economic Co-operation and Development on the tax matters of base erosion and profit shifting (or BEPS for short), for the purpose of combating tax avoidance, has entered the stage of implementation of the proposed recommendations.  On 24 November 2016, the OECD published text for a multilateral international convention under which a state will be able to quickly make changes to its numerous bilateral conventions.  The convention has been available for signing since 31 December 2016, with the first official signatories planned for the beginning of June 2017.

Noting the participation of Russia in the special group on the development of the multilateral convention, as well as in the guidance for de-offshorisation, we can expect that Russia will enter into the convention, although it is difficult to forecast how quickly this will come about. Taxpayers will be well advised to analyse the potential consequences for their business in the event that Russia signs the convention.  For further information about the multilateral convention, see the article of Elena Kilinkarova, Counsel at Maxima Legal, in Russian for the journal ‘Nalogoved’ (E. V. Kilinkarova, Multilateral convention for the realisation of the plan for BEPS – a new stage in the development of international tax law? // Nalogoved 2017. Issue 2, pages 41-48).