Most of the #DTTsInAfrica are outdated; they pre-date the existing economic conditions @URAuganda @mofpedU @maketaxfair @ICTDTax @Youth_TJN @TaxJusticeAfric
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I doubt if the OECD's MLI addresses the inequities of the allocation rules. The MLI still places emphasis on the OECD's definition of a fixed place of business for business income, and does not address the division of taxing rights over passive income.
Right. But the MLI demonstrates that DTAs can be updated in bulk rather than 1 by 1. Perhaps a similar process could be developed focused on developing countries concerns?
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Sounds good but will the MLI be as binding as DTTs?
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When countries sign up to the MLI (and their partners also sign up to the matching articles) once it has all gone through, it updates their DTAs - so just as binding -- as i understand: its like renegotiating individual articles in bulk through 'multiple choice' options
End of conversation
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