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

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
  Date unknown
  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
  Date unknown
  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

Party

Croatia modified

• added reservation
  02-10-2024
  Pursuant to Article 35(1)(b) of the Convention, Croatia notified that it intends to apply a shorter period than six calendar months with respect to the following agreement: Germany; 2 calendar months.

Germany modified

• added reservation
  02-10-2024
  A. Notification by Germany under Article 35(7)(a)(i) On 2 October 2024, 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: Croatia, France, Greece, Hungary, Malta, Slovak Republic, Spain. B. Notification by Germany under Article 35(7)(a)(vii) On 2 October 2024, as a Party to the Convention and pursuant to Article 35(7)(b) and 36 of the Convention, Germany notified the confirmation of the completion of its internal procedures for the entry into effect of the provisions of Part VI of the Convention (Arbitration) with respect to the following agreements: Greece, Hungary, Malta, Spain. Pursuant to Article 35(7)(b) of the Convention, the Depositary hereby notifies the other Contracting Jurisdictions on behalf of 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

  added reservation
  02-10-2024
  Pursuant to Article 35(1)(b) of the Convention, Germany notified that it intends to apply a shorter period than six calendar months with respect to the following agreements: Croatia, 2 calendar months; France, 2 calendar months; Greece, 2 calendar months; Hungary, 2 calendar months; Malta, 2 calendar months; Slovak Republic, 2 calendar months; Spain, 2 calendar months. The notifications 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

Greece modified

• added reservation
  02-10-2024
  Pursuant to Article 35(1)(b) of the Convention, Greece notified that it intends to apply a shorter period than six calendar months with respect to its agreement with Germany: 2 calendar months. The notifications 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

Hungary modified

• added reservation
  02-10-2024
  Pursuant to Article 35(1)(b) of the Convention, Hungary notified that it intends to apply a shorter period than six calendar months with respect to their agreement with Germany and that it intends to apply a period of two calendar months. The notifications 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

Malta modified

• added reservation
  02-10-2024
  Pursuant to Article 35(1)(b) of the Convention, Malta notified that it intends to apply a shorter period than six calendar months with respect to its agreement with Germany and that it intends to apply a period of two calendar months. The notifications 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

Slovakia modified

• added reservation
  02-10-2024
  Pursuant to Article 35(1)(b) of the Convention, the Slovak Republic notified that it intends to apply a shorter period than six calendar months with respect to its agreement with Germany and that it intends to apply a period of two calendar months. The notifications 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
  02-10-2024
  Pursuant to Article 35(1)(b) of the Convention, Spain hereby notifies that it intends to apply a shorter period than six calendar months with respect to the following agreement: Germany, 2 calendar months. The notifications 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

Mongolia modified

• Ratification: 30-09-2024 (R)
• Entry into force: 01-01-2025

• added reservation
  30-09-2024
  Pursuant to Articles 28(5) and 29(1) of the Convention, Mongolia 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

• removed reservation
  06-10-2022
  At the time of signature, pursuant to Articles 28(7) and 29(4) of the Convention, Mongolia provided a provisional list of expected reservations and notifications which are accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.

Party

Azerbaijan modified

• Ratification: 24-09-2024 (R)
• Entry into force: 01-01-2025

• added reservation
  24-09-2024
  Pursuant to Articles 28(5) and 29(1) of the Convention, Azerbaijan 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

• removed reservation
  20-11-2023
  At the time of signature, pursuant to Articles 28(7) and 29(4) of the Convention, Azerbaijan provided a list of expected reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.

Democratic Republic of the Congo modified

• Signature: 19-09-2024
• Reservations / Declarations: Yes
• Objections: No

• added reservation
  19-09-2024
  At the time of signature, pursuant to Articles 28(7) and 29(4) of the Convention, the Democratic Republic of the Congo 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

Party

Czech Republic modified

• added reservation
  16-08-2024
  a) Pursuant to Article 29(5) of the Convention, Czechia extends the list of agreements notified under Article 2(1)(a)(ii) of the Convention; b) Pursuant to Article 29(5) of the Convention, Czechia makes additional notifications under Articles 6(5), 7(17) and 16(6) of the Convention; and c) Czechia notifies a technical correction to the list of reservations and notifications deposited by Czechia upon the deposit of its instrument of ratification of the Convention on 13 May 2020. The MLI Position regarding the extended list of reservations and notifications and the notification of the technical correction 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

Algeria modified

• Signature: 27-06-2024
• Reservations / Declarations: Yes
• Objections: No

• added reservation
  27-06-2024
  At the time of signature, pursuant to Articles 28(7) and 29(4) of the Convention, Algeria provided a list of expected reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.

Party

Vietnam modified

• removed reservation
  09-02-2022
  At the time of signature, pursuant to Articles 28(7) and 29(4) of the Convention, Viet Nam provided a list of expected reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.