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

Party

Armenia modified

• Ratification: 25-09-2023 (R)
• Entry into force: 01-01-2024

Côte d'Ivoire modified

• Ratification: 25-09-2023 (R)
• Entry into force: 01-01-2024

Party

Azerbaijan modified

• Signature: 20-11-2023
• Objections: Yes
• Reservations / Declarations: No

• added 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.

Indonesia modified

• added reservation
  27-11-2023
  On 27 November 2023, as a Party to the Convention, Indonesia notified the Depositary of the following: a) Pursuant to Article 29(5) of the Convention, Indonesia extends the list of agreements notified under Article 2(1)(a)(ii) of the Convention, b) Pursuant to Articles 29(5) and 29(6) of the Convention, Indonesia makes additional notifications under Articles 4(4), 6(5), 7(17), 8(4), 9(7), 11(4), 12(5)(6), 13(7), 16(6) and 17(4) of the Convention. The Consolidated MLI Position reflecting the updated list of reservations and notifications is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.

  added reservation
  27-11-2023
  On 27 November 2023, 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: Vietnam, South Africa, Bulgaria and Mexico. On 27 November 2023, 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 withdrawal of a reservation made by the following Party with respect to their agreement: Finland. On 27 November 2023, 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 additional notification made by the following Party with respect to their agreement: Finland. The notifications made pursuant to Article 35(7)(b) are also accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.

Party

Romania modified

• added reservation
  10-11-2023
  On 10 November 2023, 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: Tunisia. The notification made pursuant to Article 35(7)(b) is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.

Spain modified

• added reservation
  10-11-2023
  On 10 November 2023, 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 agreements: Mexico, Tunisia and Vietnam. On 10 November 2023, 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 withdrawal of a reservation made by the following Party with respect to its agreement: Finland. On 10 November 2023, 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 additional notifications made by the following Party with respect to its agreement. 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

Armenia modified

• Objections: Yes

• added reservation
  25-09-2023
  Pursuant to Articles 28(6) and 29(3)of the Convention, Armenia deposited a list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.

Côte d'Ivoire modified

• Objections: Yes

• added reservation
  25-09-2023
  Pursuant to Articles 28(6) and 29(3)of the Convention, Côte d’Ivoire deposited a list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.

Eswatini modified

• Signature: 27-09-2023
• Objections: Yes
• Reservations / Declarations: No

• added reservation
  27-09-2023
  At the time of signature, pursuant to Articles 28(7) and 29(4) of the Convention, Eswatini provided a list of expected reservations and notifications which is also accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.

Serbia modified

• added reservation
  27-09-2023
  Serbia notifies the date of entry into force of the agreements with Indonesia and Morocco included in the list of agreements previously notified under Article 2(1)(a)(ii) of the Convention, The Consolidated MLI Position reflecting the updated list of reservations and notifications is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.

Party

Papua New Guinea modified

• Ratification: 31-08-2023 (R)
• Entry into force: 01-12-2023
• Objections: Yes

• added reservation
  31-08-2023
  Pursuant to Articles 28(5) and 29(1) of the Convention, Papua New Guinea deposited a list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.

Romania modified

• added reservation
  05-09-2023
  On 5 September 2023, 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: Vietnam. 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 also accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.

Party

Austria modified

• added reservation
  28-08-2023
  On 28 August 2023, as a Party to the Convention, Austria notified the Depositary of the following: a) Pursuant to Article 29(5) of the Convention, Austria extends the list of agreements notified under Article 2(1)(a)(ii) of the Convention, b) Austria notifies the date of entry into force of an agreement and 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) of the Convention Austria specifies the additional agreements falling within the scope of its reservation under Article 26(4) of the Convention, d) Pursuant to Articles 29(5) and 29(6) of the Convention Austria makes additional notifications under Articles 5(10), 6(5), 13(7), 16(6) and 17(4) of the Convention. The Consolidated MLI Position reflecting the updated list of reservations and notifications is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.

Party

Tunisia modified

• Ratification: 24-07-2023 (R)
• Entry into force: 01-11-2023
• Objections: Yes

• added reservation
  24-07-2023
  Pursuant to Articles 28(5) and 29(1) of the Convention, Tunisia deposited a list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.

Party

Finland modified

• added reservation
  27-06-2023
  Pursuant to Article 29(6) of the Convention, Finland makes additional notifications under Article 9(7) and (8) of the Convention. Pursuant to Article 28(9) of the Convention, Finland withdraws the reservation made under Article 9(6) of the Convention. The Consolidated MLI Position reflecting the updated list of reservations and notifications is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.

Japan modified

• added reservation
  20-06-2023
  a) Pursuant to Article 29(5) of the Convention, Japan extends the list of agreements notified under Article 2(1)(a)(ii) of the Convention; and b) Pursuant to Article 29(5) of the Convention, Japan makes additional notifications under Articles 4(4), 6(5), 6(6), 9(7), 12(5), 12(6), 13(7), 16(6)(a), 16(6)(b)(ii), and 17(4) of the Convention. The Consolidated MLI Position reflecting the updated list of reservations and notifications is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.

New Zealand modified

• added reservation
  20-06-2023
  On 20 June 2023, as a Party to the Convention, New Zealand notified the Depositary of two corrections to the list of reservations and notifications deposited by New Zealand upon the deposit of its instrument of ratification of the Convention on 27 June 2018. The corrected list of reservations and notifications made by New Zealand pursuant to Articles 28(5) and 29(1) of the Convention is now available at http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.

Romania modified

• added reservation
  03-07-2023
  On 3 July 2023, 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: Mexico. 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 also accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.

Party

Spain modified

• added reservation
  01-06-2023
  On 1 June 2023, 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 agreements: Bulgaria and South Africa. 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

Vietnam modified

• Ratification: 23-05-2023 (R)
• Entry into force: 01-09-2023

• added reservation
  23-05-2023
  Pursuant to Articles 28(5) and 29(1) of the Convention, Viet Nam deposited a list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.