Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (Multilateral Instrument)


The multilateral Instrument (the MLI), developed by the OECD and endorsed by the G20, offers concrete solutions for governments to close the gaps in existing international tax rules by transposing results from the OECD/G20 BEPS Project into bilateral tax treaties worldwide. The MLI modifies the application of thousands of bilateral tax treaties concluded to eliminate double taxation.


See the official texts of the MLI [read] and the Explanatory Statement [read].

See also the legal notes on the functioning of the MLI under Public international law [read].

See MLI positions below



Multilateral Instrument (the MLI) and MLI Positions


Under the provisions of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS, each jurisdiction is required to provide a list of reservations and notifications (the "MLI Position") at the time of signature.


Each Signatory must prepare and submit its "MLI Position" before signing the MLI. The MLI Position sets out all of the Signatory's choices with respect to the different options provided for in the MLI. 


The MLI Positions provided at the time of signature for the jurisdictions may be subject to changes. The definitive position for each jurisdiction will be provided upon the deposit of its instrument of ratification, acceptance or approval of the above-mentioned Multilateral Convention.


The MLI Position provided for each jurisdiction is available in the table of reservations and notifications [read]









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