Before 2017, there were two major international movements going on at the same time: (1) the Trans-Pacific Partnership (TPP) Agreement; and (2) the Organization for Economic Cooperation and Development’s (OECD’s) Base Erosion and Profit Shifting (BEPS) Project. The movements presented a...

The OECD recommended various rules that countries can adopt to combat hybrid mismatch arrangements in their domestic tax system. However, its success would not come when the integrity measure, namely “imported mismatch rules”, does not operate as intended. This article examines how the...

The article argues that despite the fanfare around it, the outcome of the BEPS project is unlikely to be dramatic, at least in the short term. Beyond a period of increased legal uncertainty and aggressive enforcement by some countries, it expects little substantive change in tax treaties. The...

The OECD's goal in Action 14 of the BEPS Action Plan — of making dispute resolution mechanisms more effective — is a major aspect of the evolving transnational regime for tax. One of the most central questions is whether mandatory arbitration will be established. As international taxation is...

This article examines the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) in relation to fiscally transparent entities; specifically limited partnerships which are taxed as flow through entities in one jurisdiction but as...

Under the BEPS Action 5 minimum standard, members of the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting (BEPS) have committed to counter harmful tax practices with a focus on improving transparency. One part of the Action 5 minimum standard is the transparency framework for...