Opening Remarks by Angel Gurría
Paris, France, 7 June 2017
(As prepared for delivery)
Your Excellencies, Ladies and Gentlemen:
We are about to make tax treaty history! Before you lies the first‑ever multilateral instrument capable of amending bilateral tax treaties: the Multilateral Convention on Tax Treaty Related Measures to Prevent BEPS. Tonight, more than 70 countries and jurisdictions have come together to join the Convention, with more expected to follow in the coming months. I commend each of you ─ and the countries you represent ─ for your commitment to delivering a stronger, fairer global tax system.
Less than two years ago, we finalised the BEPS Package to fix international tax loopholes that collectively cost countries up to USD 240 billion in foregone revenue ─ or around 10% of global corporate tax revenues ─ every year. The BEPS Package catalysed the largest, and fastest, rewriting of the international tax rules in a century. One of the most concerning types of BEPS arrangements that we sought to address was treaty shopping – using third jurisdictions, which would otherwise not be part of a transaction, simply to access the treaty benefits.
This Convention puts an end to treaty shopping and will provide taxpayers with greater certainty through improvements to the Mutual Agreement Procedures. It also gives you the tools needed to implement mandatory binding arbitration, tackle hybrid mismatches, and stop artificial avoidance of “permanent establishment” status in your countries. And, crucially, it goes to the heart of our efforts during this year’s MCM to help restore citizens’ trust in the fairness and transparency of global governance systems and the legitimacy of the processes underpinning global integration.
Renegotiating tax treaties has always been a significant hurdle. It’s time-consuming, resource-intensive, and cumbersome. And that’s what makes this Convention so remarkable. Tonight, with the strokes of your pens, you will begin amending more than 1100 tax treaties. This would normally have taken decades! In moving so quickly, we have taken a big step towards levelling the global playing field. Tax treaties will now be fit for purpose, eliminating double taxation without creating opportunities for non-taxation or reduced taxation through tax evasion or avoidance.
Ladies and Gentlemen:
We now move to the most important part of tonight’s ceremony, the signature. It is time to make tax treaty history!
Press release: Ground-breaking multilateral BEPS convention signed at OECD will close loopholes in thousands of tax treaties worldwide
OECD work on Base erosion and profit shifting (BEPS)