Untangling the Role of Reservations in the OECD Multilateral Instrument: The OECD Legal Hybrids
Journal
Country
International; OECD
Published Date
Issue
Bulletin for International Taxation 2017 (Volume 71), No. 10
Document
By elaborating a typology and unearthing the effects of the MLI reservations, the author concludes that the OECD is shifting away from the Vienna Convention on the Law of Treaties to endorse unknown legal categories, thereby concealing the lack of consensus regarding how best to deal with base erosion and profit shifting practices.