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

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
• Objections: Yes
• Reservations / Declarations: 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
• Objections: Yes
• Reservations / Declarations: 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.

Party

Spain modified

• added reservation
  31-05-2024
  On 31 May 2024, as a Party to the Convention and pursuant to Article 35(7)(b) of the Convention, Spain notified the confirmation of the completion of internal procedures for the entry into effect of the provisions of the Convention with respect to the following agreement: Armenia. 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

China modified

• added reservation
  22-02-2024
  On 22 February 2024, as a Party to the Convention and pursuant to Article 35(7)(b) of the Convention, the People’s Republic of China on behalf of Hong Kong (China) notified the confirmation of the completion of internal procedures for the entry into effect of the provisions of the Convention with respect to Hong Kong (China)’s following agreements: Mexico and Vietnam. 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.

Russian Federation modified

• added reservation
  09-02-2024
  On 17 January 2024, as a Party to the Convention and pursuant to Article 35(7)(b) of the Convention, the Russian Federation 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: Armenia, Hong Kong, Mexico, Romania and Viet Nam. 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

Romania modified

• added reservation
  11-01-2024
  On 11 January 2024, 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: Armenia. 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

Malaysia modified

• added reservation
  28-11-2023
  Pursuant to Article 35(5)(b) of the Convention and as a Party to the Convention, Malaysia notified that it intends to apply a shorter period of thirty days with respect to its agreement with Poland.

Poland modified

• added reservation
  28-11-2023
  Pursuant to Article 35(5)(b) of the Convention and as a Party to the Convention, Poland notified that it intends to apply a shorter period of thirty days with respect to its agreement with Malaysia.