Download the Q2, 2023 edition of our quarterly international tax publication, Global Tax Insights, produced by Morison Global's tax experts.


BEPS Action plan 6 identified treaty shopping and treaty abuse as one of the principal concerns and therefore this was agreed as a minimum standard by all the participating countries. The countries also agreed to subject their efforts to an annual peer review. The fifth peer review report reveals that the members are respecting their commitment to implement the minimum standard on treaty shopping and confirms implementation of the multilateral instrument (MLI) as the tool adopted by majority of the jurisdictions for this purpose. The report further reveals that the impact and coverage of the MLI is expected to continue to increase as jurisdictions complete their ratifications.

As per the report MLI covers 100 jurisdictions and around 1,850 bilateral treaties. In a significant move, the Australian government announced its decision to implement 15% global minimum tax for large multinational enterprises with the income inclusion rule (IIR) applicable to income years starting on or after 1 January 2024 and the undertaxed profits rule (UTPR) applying to income years starting on or after 1 January 2025. Other countries – for instance, Belgium, South Africa and New Zealand – have also started taking steps to change their domestic legislation in conformity with the BEPS Pillar 2 recommendations.

As mentioned in the Q1 2023 editorial the UAE Corporate Tax (CT) Law has begun its innings from June 2023. To facilitate implementation, the authorities have issued several clarifications in the form of Cabinet and Ministerial Decisions. This issue of Global Tax Insights contains an article on the transfer pricing regime in the Emirates introduced as part of the UAE CT Law, alongside other articles on important tax issues.

The minimum standard on treaty shopping now covers 100 jurisdictions and around 1,850 bilateral treaties

Signing off with the following thought:

Trying to maintain control in this life is a bit like trying to maintain control on a roller coaster. The ride has its own logic and is going to go its own way, regardless of how tightly you grip the bar. There is a thrill and a power in simply surrendering to the ride and fully feeling the ups and downs of it, letting the curves take you rather than fighting them. When you fight the ride, resisting what’s happening at every turn, your whole being becomes tense and anxiety is your close companion. When you go with the ride, accepting what you cannot control, freedom and joy will inevitably arise.

Happy reading!

Sachin Vasudeva
SCV & Co. LLP, India

Download the Q2, 2023 edition