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International tax: A year of transition

Author(s): Monica Biringer, Patrick Marley, Drew Morier, Kaitlin Gray

Dec 13, 2019

In 2019, global efforts towards international tax reform – spearheaded by the G20 and the OECD – continued to move forward. Two developments in particular are expected to have a major impact in Canada.

First, on December 1, 2019, the Multilateral Instrument (MLI) entered into force in Canada. The MLI – formally the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting – makes significant amendments to many of Canada’s bilateral tax treaties. Chief among these is the adoption of the OECD-agreed mandatory “minimum standards” on tax treaty abuse. Also significant is Canada’s choice to opt into mandatory binding arbitration for tax treaty disputes.