| Competent authority (CA) |
Person authorised by a double tax agreement (DTA) to administer tax treaty provisions and resolve disputes. |
| Compatibility clauses |
Implementation clauses that explain how CTAs are modified by operative clauses. |
| Covered tax agreement (CTA) |
A DTA that both parties have chosen to be modified by the MLI. |
| Double tax agreement (DTA) |
A bilateral tax treaty. |
| Explanatory statement |
Commentary accompanying the MLI to explain the operation of the instrument. It does not address substantive issues – these are covered by the relevant OECD Action Report. |
| MAP |
Mutual Agreement Procedure. |
| Minimum standards |
BEPS Action Plan recommendations countries are expected to adopt (for example, the DTA preamble). |
| Multilateral instrument (MLI) |
The OECD Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting. |
| Notifications |
Each jurisdiction must provide a list of CTAs, options chosen, reservations and articles of CTAs modified by the MLI to the OECD Depository. |
| OECD |
Organisation for Economic Cooperation and Development. |
| Operative clauses |
Clauses that implement substantive changes to treaties as per the Action Plan recommendations. |
| Options |
Some Action Plan items allow countries choices (for example, methods to relieve double taxation). |
| Reservations |
Countries are permitted to reserve on non-minimum standard clauses. |
