Abstract

CIPRIANI, Elva Felicia Reátegui. MULTINATIONAL CORPORATIONS IN THE FRAMEWORK OF ACTION 15 OF BEPS. Revista Internacional CONSINTER de Direito [online]. 2020, n.10, pp.219-242.  Epub June 30, 2020. ISSN 2183-6396.  https://doi.org/10.19135/revista.consinter.00010.10.

Multinational corporations should keep in mind that in the international taxation area a firm step has been taken with the recent signing of the Multilateral Instrument - IML - to avoid tax avoidance through the modification of tax agreements. This agreement already in force, was signed on June 7, 2017 in Paris by 76 jurisdictions, including Spain and modifies from approx. 1.105 tax agreements to avoid double taxation - CDIs - in a synchronized, fast and efficient way.

The IML is part of the dissertation promoted by the OECD 5 at the request of the G-20 in which a Plan with 15 actions to be followed is determined to avoid the BEPS (Base Erosion and Profit Shifting). This instrument is a revolution for international taxation that was aimed at the prevention of double taxation and goes on to fight against double taxation or abuse of treaties by curbing the aggressively planned tax avoidance that multinational corporations carry out.

Keywords : Multilateral convention to implement tax treaty related measures to prevent base erosion and profit shiffting; BEPS Action Plan; treaty abuse; tax avoidance; agreement to avoid double taxation; multinational corporations.

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