2. Preventing the granting Preamble language minimum standard Yes Yes Same as New Zealand – of treaty benefits in The MLI will amend the preamble to DTAs to emphasise that as well as aiming to inappropriate relieve double taxation, the treaty also aims to prevent opportunities for non-taxation, circumstances (Action 6 reduced taxation or tax avoidance. report) Article 6(1) and (2) of the MLI Preamble language optional amendment No No Different to New – Zealand. The MLI allows countries to adopt the following optional amendment to the preamble to DTAs: Adopt to further develop their economic relationship and to enhance their “Desiring in tax matters,” Article 6(3) and (6) of the MLI
2. Preventing the granting of treaty benefits in inappropriate circumstances (Action 6 report) Preamble language – minimum standard The MLI will amend the preamble to DTAs to emphasise that as well as aiming to relieve double taxation, the treaty also aims to prevent opportunities for non-taxation, reduced taxation or tax avoidance. Article 6(1) and (2) of the MLI Yes Yes Same as New Zealand Preamble language – optional amendment The MLI allows countries to adopt the following optional amendment to the preamble to DTAs: “Desiring to further develop their economic relationship and to enhance their in tax matters,” Article 6(3) and (6) of the MLI No No Different to New Zealand. Adopt
2017-other-beps-04-report-ir2017-260-mli-april-2017.docx