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PE Watch: Latest developments and trends, January 2021

14 January 2021

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Tax Alerts, Legislation & Policy, National/Federal Taxation, Treaties, OECD

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United States, Barbados, Finland, France, Germany, India, Pakistan, Portugal, Switzerland, Ukraine

OECD BEPS Multilateral InstrumentOn 18 December 2020, Germany and Pakistan deposited their instrument of ratification of the Multilateral Instrument (MLI) with the Organisation for Economic Co-operation and Development (OECD). Germany confirmed its preliminary positions regarding the PE provisions in which it only chose to apply Article 13(1) Option A (the list of activities, or the combination thereof, is restricted to activities of a preparatory or auxiliary character). Germany also removed 22 tax treaties from its list of Covered Tax Agreements (CTAs) and added the tax treaty with Greece. Pakistan changed its preliminary positions regarding the PE provisions by removing the reservations on...