BEPS Multilateral Instrument (MLI)
Recently, Egypt, Burkina Faso, and Panama deposited their instruments of ratification for the Multilateral Instrument (MLI) and confirmed their preliminary positions with respect to the permanent establishment (PE) provisions, respectively. As regards to the PE positions, Egypt and Burkina Faso have adopted all PE provisions, with the exception of Article 14 (contract splitting rule) that Egypt chose not to apply with respect to provisions of its Covered Ta…