Australia and Canada Sign Memorandum of Understanding on Arbitration under BEPS MLI

The Australian Taxation Office (ATO) has published a Memorandum of Understanding signed with Canada on the mode of application for the implementation of Part VI (Arbitration) of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). This includes sections on arbitration requests, minimum information requirements, the appointment of arbitrators, the arbitration process, etc. The Memorandum of Understanding was signed by Australi…