Canada and France Sign Competent Authority Arrangement on Arbitration Under BEPS MLI

The Canada Revenue Agency has published a Competent Authority Arrangement signed with France to establish the mode of application of the arbitration process provided for in Part VI of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). The arrangement is entered into pursuant to Article 25 (Mutual Agreement Procedure) of the 1975 tax treaty between the two countries as modified by Article 16 and paragraph 10 of Article 19 of…