Methods of Avoiding Double Taxation under the Multilateral Convention to Implement Tax Treaty-Related Measures (MLI)

  • Marcin Jamroży SGH, Instytut Finansów, Zakład Podatków
Keywords: multilateral instrument (MLI); BEPS; tax credit; tax exemption; tax treaty abuse


The objective of this article is to present the solutions adopted in the Multilateral Convention to implement tax treaty-related measures to prevent base erosion and profit shifting. It also assesses the solutions, taking into account the final tax burden of the taxpayer’s income. The far wider application of the ordinary tax credit method and the instruments to limit the abuse of double taxation treaties are consistent with the current Polish tax policy aims. The amendments provided for in the Multilateral Convention ensure Capital Export Neutrality (CEN).

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