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

Party

Tunisia modified

• Ratification: 24-07-2023 (R)
• Entry into force: 01-11-2023
• Reservations / Declarations: 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.

Party

Slovenia modified

• added reservation
  23-03-2023
  On 23 March 2023, as a Party to the Convention and pursuant to Article 29(5) of the Convention, Slovenia notified the Depositary of the date of entry into force of an agreement 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

Mexico modified

• Reservations / Declarations: Yes

• added reservation
  15-03-2023
  Pursuant to Articles 28(5) and 29(1) of the Convention, Mexico 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

Mexico modified

• Ratification: 15-03-2023 (R)
• Entry into force: 01-07-2023

Party

Portugal modified

• added reservation
  06-03-2023
  On 6 March 2023, as a Party to the Convention and pursuant to Article 29(5) of the Convention, Portugal notified the Depositary of the date of entry into force of an agreement 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.

Romania modified

• added reservation
  06-03-2023
  On 6 March 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 agreements: Albania, Australia, Austria, Belgium, Bosnia and Herzegovina, Bulgaria, Canada, China (People’s Republic of), Croatia, Cyprus, Czech Republic, Denmark, Egypt, Estonia, Finland, France, Georgia, Greece, Hong Kong (China), Hungary, Iceland, India, Indonesia, Ireland, Israel, Japan, Jordan, Kazakhstan, Korea, Latvia, Lithuania, Luxembourg, Malaysia, Malta, Netherlands, Norway, Pakistan, Poland, Portugal, Qatar, Russian Federation, San Marino, Saudi Arabia, Serbia, Singapore, Slovak Republic, Slovenia, South Africa, Spain, Sweden, Thailand, Ukraine, United Arab Emirates, United Kingdom and Uruguay. Pursuant to Article 35(7)(b) of the Convention, the Depositary hereby notifies the other Contracting Jurisdictions 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

China modified

• added reservation
  21-02-2023
  On 21 February 2023, 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 the following agreements: Austria, Belgium, Canada, Czech Republic, France, Guernsey, Hungary, India, Indonesia, Ireland, Japan, Jersey, Korea, Latvia, Liechtenstein, Luxembourg, Malaysia, Malta, Netherlands, New Zealand, Pakistan, Portugal, Qatar, Romania, Russian Federation, Saudi Arabia, South Africa, Spain, Thailand, United Arab Emirates and United Kingdom. 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
  21-02-2023
  On 7 February 2023, 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: Bulgaria, People’s Republic of China, South Africa, Spain and Thailand. 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

Switzerland modified

• added reservation
  16-12-2022
  On 16 December 2022, as a Party to the Convention and pursuant to Article 35(7)(b) of the Convention, Switzerland 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: Iceland. 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.