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

Party

Georgia modified

• added reservation
  01-01-1
  a) Pursuant to Article 29(5) of the Convention, Georgia extends the list of agreements notified under Article 2(1)(a)(ii) of the Convention, b) Pursuant to Article 29(5) of the Convention, Georgia specifies the additional agreements falling within the scope of its reservation under Article 17(3) of the Convention, c) Pursuant to Article 29(5) of the Convention, Georgia makes additional notifications under Article 6(5) Article 6(6), Article 7(17) and Article 16(6) of the Convention. The Consolidated MLI Position reflecting the updated list of reservations and notifications is accessible on the OECD website: https://www.oecd.org/content/dam/oecd/fr/topics/policy-sub-issues/im-beps/beps-instrument-multilateral-signataires-et-parties.pdf.

Party

Brazil modified

• Objections: Yes

• added reservation
  01-01-1
  At the time of signature, pursuant to Articles 28(7) and 29(4) of the Convention, Brazil provided a provisional list of expected reservations and notifications which is accessible on the OECD website: https://www.oecd.org/content/dam/oecd/en/topics/policy-sub-issues/beps-mli/beps-mli-signatories-and-parties.pdf.

Montenegro modified

• Signature: 12-11-2025
• Objections: Yes
• Reservations / Declarations: No

• added reservation
  01-01-1
  At the time of signature, pursuant to Articles 28(6) and 29(3) of the Convention, Montenegro provided a list of expected reservations and notifications which is accessible on the OECD website: https://www.oecd.org/content/dam/oecd/en/topics/policy-sub-issues/beps-mli/beps-mli-signatories-and-parties.pdf.

Ukraine modified

• added reservation
  01-01-1
  a) Pursuant to Article 29(5) of the Convention, Ukraine extends the list of agreements notified under Article 2(1)(a)(ii) of the Convention, b) Ukraine notifies the date of entry into force of amending instruments included in the list of agreements previously notified under Article 2(1)(a)(ii) of the Convention, c) Pursuant to Article 29(5) and 29(6) of the Convention, Ukraine makes additional notifications under Articles 6(5), 7(17), 9(7), 12(5)(6), 13(7), 14(4) and 16(6) of the Convention. The Consolidated MLI Position reflecting the updated list of reservations and notifications is accessible on the OECD website: https://www.oecd.org/content/dam/oecd/en/topics/policy-sub-issues/beps-mli/beps-mli-signatories-and-parties.pdf.

Party

Brazil added

• Signature: 20-10-2025
• Objections: No
• Reservations / Declarations: No

Party

Argentina modified

• Objections: Yes

• added reservation
  01-01-1
  Pursuant to Articles 28(5) and 29(1) of the Convention, Argentina deposited a list of reservations and notifications which is also accessible on the OECD website: https://www.oecd.org/content/dam/oecd/en/topics/policy-sub-issues/beps-mli/beps-mli-signatories-and-parties.pdf

Party

Argentina modified

• Ratification: 29-09-2025 (R)
• Entry into force: 01-01-2026

Party

Antigua and Barbuda modified

• Signature: 18-06-2025
• Objections: Yes
• Reservations / Declarations: No

• added reservation
  01-01-1
  At the time of signature, pursuant to Articles 28(7) and 29(4) of the Convention, Antigua and Barbuda provided a list of expected reservations and notifications which is accessible on the OECD website: https://www.oecd.org/content/dam/oecd/en/topics/policy-sub-issues/beps-mli/beps-mli-signatories-and-parties.pdf.

Peru modified

• Ratification: 09-06-2025 (R)
• Entry into force: 01-10-2025
• Objections: Yes

• added reservation
  01-01-1
  Pursuant to Articles 28(5) and 29(1) of the Convention, Peru deposited a list of reservations and notifications which is also accessible on the OECD website: https://www.oecd.org/content/dam/oecd/en/topics/policy-sub-issues/beps-mli/beps-mli-signatories-and-parties.pdf

Party

Germany modified

• added reservation
  26-05-2025
  Notification by Germany under Article 35(7)(a)(i) On 26 May 2025, as a Party to the Convention and pursuant to Article 35(7)(b) of the Convention, Germany notified the confirmation of the completion of its internal procedures for the entry into effect of the provisions of the Convention with respect to the following agreements: Czech Republic and Japan. The deposit of this notification takes effect on 1 June 2025 as requested by Germany. The notifications made pursuant to Article 35(7)(b) are accessible on the OECD website: https://www.oecd.org/content/dam/oecd/en/topics/policy-sub-issues/beps-mli/beps-mli-signatories-and-parties.pdf .

Spain modified

• added reservation
  26-05-2025
  Notification by Spain under Article 35(7)(a)(i): On 26 May 2025, as a Party to the Convention and pursuant to Article 35(7)(b) of the Convention, Spain notified the confirmation of the completion of its internal procedures for the entry into effect of the provisions of the Convention with respect to the following agreement: Azerbaijan. The notifications made pursuant to Article 35(7)(b) are accessible on the OECD website: https://www.oecd.org/content/dam/oecd/en/topics/policy-sub-issues/beps-mli/beps-mli-signatories-and-parties.pdf .

Party

Kenya modified

• Ratification: 08-01-2025 (R)
• Entry into force: 01-05-2025

• added reservation
  01-01-1
  Pursuant to Articles 28(5) and 29(1) of the Convention, Kenya deposited a list of reservations and notifications which is also accessible on the OECD website: https://www.oecd.org/content/dam/oecd/en/topics/policy-sub-issues/beps-mli/beps-mli-signatories-and-parties.pdf.

Romania modified

• added reservation
  01-01-1
  Notification by Romania under Article 35(7)(a)(i) On 10 January 2025, as a Party to the Convention and pursuant to Article 35(7)(b) of the Convention, Romania notified the confirmation of the completion of its internal procedures for the entry into effect of the provisions of the Convention with respect to the following agreement: Azerbaijan. Pursuant to Article 35(7)(b) of the Convention, the Depositary hereby notifies the other Contracting Jurisdiction on behalf of Romania. The notifications made pursuant to Article 35(7)(b) are accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.

Party

France modified

• added reservation
  13-11-2024
  Pursuant to Article 35(1)(b) of the Convention, France notified that it intends to apply a shorter period than six calendar months with respect to the following agreement: Germany, 2 calendar months. The notification is accessible on the OECD website: https://www.oecd.org/content/dam/oecd/en/topics/policy-sub-issues/beps-mli/beps-mli-signatories-and-parties.pdf.

Party

Indonesia modified

• added reservation
  29-10-2024
  On 29 October 2024, as a Party to the Convention and pursuant to Article 35(7)(b) of the Convention, Indonesia notified the confirmation of the completion of its internal procedures for the entry into effect of the provisions of the Convention with respect to the following agreement: Armenia. On 29 October 2024, as a Party to the Convention and pursuant to Article 35(7)(b) of the Convention, Indonesia notified the confirmation of the completion of its internal procedures for the entry into effect of the provisions of the Convention with respect to the following agreements resulting from an extension pursuant to Article 29(5) of the Convention of the list of agreements notified under Article 2(1)(a)(ii): Jordan, Papua New Guinea, Tunisia and Ukraine. Pursuant to Article 35(7)(b) of the Convention, the Depositary hereby notifies the other Contracting Jurisdictions on behalf of Indonesia. The notifications made pursuant to Article 35(7)(b) are accessible on the OECD website: https://www.oecd.org/content/dam/oecd/en/topics/policy-sub-issues/beps-mli/beps-mli-signatories-and-parties.pdf