OECD issues beta version of the Matching Database for the Multilateral Convention to Implement Tax Treaty Related Measures
On 11 July 2017, the Organisation of Economic Co-operation and Development (OECD) issued the beta version of the matching database for the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (the “MLI”). This comes on the back of widespread support of the MLI, with Mauritius and Cameroon signing the treaty in early July, bringing the total number of signatories to 70.
Singapore signed the MLI on 7 June 2017, as an early adopter, and lodged with the OECD a provisional list of reservations and notifications. Consistent with its commitments as a member of the inclusive framework for implementing measures to counter base erosion and profit shifting (BEPS), Singapore has adopted the MLI articles relating to preventing treaty abuse (adopting the principal purpose test) and enhancing dispute resolution. It has also adopted the mandatory binding arbitration (choosing the final offer option). At the same time of signing, 68 of Singapore’s 82 in-force double tax agreements (DTAs) have been identified as the covered tax agreements to be updated through the MLI. It should be noted that while Mauritius has signed the MLI, the Singapore-Mauritius DTA has not been listed by Mauritius as a covered tax agreement.