Authentic Languages and Official Translations of the Multilateral Instrument and Covered Tax Agreements

Authentic Languages and Official Translations of the Multilateral Instrument and Covered Tax Agreements
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Total Pages : 27
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ISBN-10 : OCLC:1300900443
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Book Synopsis Authentic Languages and Official Translations of the Multilateral Instrument and Covered Tax Agreements by : Josef Schuch

Download or read book Authentic Languages and Official Translations of the Multilateral Instrument and Covered Tax Agreements written by Josef Schuch and published by . This book was released on 2019 with total page 27 pages. Available in PDF, EPUB and Kindle. Book excerpt: The authentic languages of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (commonly referred to as the multilateral instrument, MLI) are French and English, both languages being equally authentic. The MLI modifies hundreds of bilateral double taxation conventions (hereinafter 'tax treaties'). These tax treaties have their own authentic languages, often the official languages of the contracting states, which might be different than French and English. This leads to complicated situations. For example Austria and Italy have indicated that they wish to modify the 1981 Austria-Italy tax treaty by the MLI. The authentic languages of that tax treaty are German and Italian. As a consequence, when one wants to consult the Austria-Italy tax treaty as modified by the MLI, the original provisions of the tax treaty are authentic in German and Italian, whereas the provisions modified by the MLI are authentic in French and English. As a result, it is possible that some paragraphs of a certain provision of the tax treaty are authentic only in German and Italian, while some other paragraphs of that provision as modified by the MLI are authentic only in French and English. Immediately questions arise as to how one should interpret those tax treaties which do not have French and English as their authentic languages and which are modified by the MLI, and how interpretation issues related to different authentic language versions should be resolved. This contribution will provide answers to these questions.


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