The Proposed OECD Multilateral Instrument Amending Tax Treaties

In this article, the authors consider some of the practical issues relating to the introduction of the OECD multilateral instrument amending tax treaties, which has been proposed within the context of the OECD/G20 Base Erosion and Profit Shifting Project

Dual Residence of Companies under Tax Treaties

This article provides critical re\ufb02ections on the 2017 revision of article 4(3) of the OECD Model Convention and its Commentary regarding dual residence of persons other than individuals. These changes and their implementation warrant an assessment of their desirability, including an in-depth review of their impact on other provisions of the OECD Model, as well as the (re)consideration of alternative mechanisms to resolve dual-residence situations. In the light of the above, this article provides a comprehensive analysis of the evolution of rules governing dual residence of companies formed by incorporation and addresses, from a policy as well as a legal perspective, the main criticalities associated with the above-mentioned revisions, most notably the overarching legal uncertainty that such amendments may generate, the potential instances of international double taxation that may arise therefrom and the excessive discretion with which competent authorities would be entrusted in dealing with the matter, a circumstance against which taxpayers may be left with very limited judicial remedies

Low dose mifepristone and two regimens of levonorgestrel for emergency contraception: A WHO multicentre randomised trial

Background: A single 10 mg dose of mifepristone, and two 0.75 mg doses of levonorgestrel 12 h apart, are effective for emergency contraception. Because no studies had compared the efficacies of both compounds, or investigated a single dose of 1.5 mg levonorgestrel, we undertook this three-arm trial. Methods: We did a randomised, double-blind trial in 15 family-planning clinics in 10 countries. We randomly assigned 4136 healthy women with regular menstrual cycles, who requested emergency contraception within 120 h of one unprotected coitus, to one of three regimens: 10 mg single-dose mifepristone; 1.5 mg single-dose levonorgestrel; or two doses of 0.75 mg levonorgestrel given 12 h apart. The primary outcome was unintended pregnancy; other outcomes were side-effects and timing of next menstruation. Analysis was by intention to treat, but we did exclude some patients from the final analyses. Findings: Of 4071 women with known outcome, pregnancy rates were 1.5% (21/1359) in those given mifepristone, 1.5% (20/1356) in those assigned single-dose levonorgestrel, and 1.8% (24/1356) in women assigned two-dose levonorgestrel. These proportions did not differ significantly (p=0.83). The relative risk of pregnancy for single-dose levonorgestrel compared with two-dose levonorgestrel was 0.83 (95% CI 0.46-1.50), and that for levonorgestrel (the two regimens combined) compared with mifepristone, 1.05 (0.63-1.76). Side-effects were mild and did not differ greatly between groups, and most women menstruated within 2 days of the expected date. Women who took levonorgestrel had earlier menses than did those who took mifepristone. Interpretation: The three regimens studied are very efficacious for emergency contraception and prevent a high proportion of pregnancies if taken within 5 days of unprotected coitus. Mifepristone and levonorgestrel do not differ in efficacy. A 1.5 mg single levonorgestrel dose can substitute two 0.75 mg doses 12 h apart.link_to_subscribed_fulltex