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United Kingdom
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Key definition
OECD definition

What does OECD mean? In legal practice, “OECD” refers to the Organisation for Economic Co‑operation and Development, an intergovernmental body of 38 member countries (including the UK and Ireland) whose economic research, standards and policy recommendations often shape domestic law, treaty practice and compliance. The term is descriptive rather than a defined legal term; however, UK and Irish legislation, regulations and treaties frequently incorporate or refer to OECD instruments. Key touchpoints include: - Tax: the OECD Model Tax Convention, OECD Transfer Pricing Guidelines (used by HMRC and Irish Revenue as interpretative guidance), the BEPS project and Pillar Two/GloBE rules implemented in both jurisdictions. -...

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BEPS Multilateral Instrument: Practical guide to operation, effective dates, synthesised texts and key provisions, with UK position and checklist for assessing treaty modifications

Published by a LexisNexis Tax expert
Practice notes
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The Organisation for Economic Co-operation and Development’s Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting—better known as the BEPS Multilateral Instrument (MLI)—puts into effect those BEPS Actions that necessitate amendments to double tax treaties (DTTs), avoiding the need to renegotiate each treaty individually. When a taxpayer intends to rely on a DTT, their adviser should review whether the pertinent article is impacted by the MLI. This is clearest where the MLI expressly adjusts a provision, such as rules on permanent establishments or hybrid entities, but it is equally vital to consider how the MLI’s treaty abuse provisions might influence access to other treaty advantages. For instance, although the MLI does not rewrite treaty articles on dividends or interest, the principal purpose test can still withhold benefits those articles might otherwise grant. The UK, in common with other MLI signatories, has released ‘synthesised texts’ of its DTTs to show how specific treaties are affected by the MLI.

This Practice Note:

  • sets out background on the MLI and its position in...
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Web page updated on 21/05/2026

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