Multilateraal Verdrag ter implementatie van aan belastingverdragen gerelateerde maatregelen ter voorkoming van grondslaguitholling en winstverschuiving

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Uitbreiding

China

Verenigd Koninkrijk

Albanië

22-09-2020

Pursuant to Articles 28(5) and 29(1) of the Convention, Albania deposited its list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.

Algerije

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.

Andorra

29-09-2021

Pursuant to Articles 28(5) and 29(1) of the Convention, Andorra 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.

Antigua en Barbuda

18-06-2025

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.

Argentinië

29-09-2025

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

Armenië

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.

Australië

26-09-2018

Pursuant to Articles 28(5) and Article 29(1) of the Convention, Australia deposited its list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.

Azerbeidzjan

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

Bahrein

23-02-2022

Pursuant to Articles 28(5) and 29(1) of the Convention, Bahrain 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.

Barbados

21-12-2020

Pursuant to Articles 28(5) and 29(1) of the Convention, Barbados 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.

België

26-06-2019

Pursuant to Articles 28(6) and Article 29(3) of the Convention, Belgium deposited its list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.

25-11-2021

Pursuant to paragraphs 1(b) and (5)(b) of Article 35 of the Convention, the Kingdom of Belgium notifies that it intends to apply a shorter period with respect to the following agreement: the Convention between the Kingdom of the Netherlands and the Kingdom of Belgium for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital: one calendar month and six days.
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.

Belize

07-04-2022

Pursuant to Articles 28(5) and 29(1) of the Convention, Belize 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.

Bosnië en Herzegovina

16-09-2020

Pursuant to Articles 28(5) and 29(1) of the Convention, Bosnia and Herzegovina deposited its list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.

Brazilië

20-10-2025

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.

Bulgarije

16-09-2022

Pursuant to Articles 28(5) and 29(1) of the Convention, Bulgaria 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.

Burkina Faso

30-10-2020

Pursuant to Articles 28(5) and 29(1) of the Convention, Burkina Faso deposited its list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.

Canada

29-08-2019

Pursuant to Articles 28(5) and Article 29(1) of the Convention, Canada deposited its list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.

Chili

26-11-2020

Pursuant to Articles 28(6) and 29(3) of the Convention, Chile deposited its list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.

China

25-05-2022

Pursuant to Articles 28(5) and 29(1) of the Convention, China deposited a list of reservations and notifications. Pursuant to Articles 28(4), 28(5), 29(1) and 29(2), China deposited a separate list of reservations in respect of Hong Kong (China). Both lists are accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.

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.

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.

Congo, Democratische Republiek

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

Costa Rica

22-09-2020

Pursuant to Articles 28(5) and 29(1) of the Convention, Costa Rica deposited its list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.

Cyprus

23-01-2020

Pursuant to Articles 28(5) and Article 29(1) of the Convention, Cyprus deposited its list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.

Denemarken

30-09-2019

Pursuant to Articles 28(5) and Article 29(1) of the Convention, Denmark deposited its list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.

Duitsland

18-12-2020

Pursuant to Articles 28(5) and 29(1) of the Convention, Germany deposited its list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.

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

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

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 .

Egypte

30-09-2020

Pursuant to Articles 28(6) and 29(3) of the Convention, Egypt deposited its list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.

Estland

15-01-2021

Pursuant to Articles 28(6) and 29(3) of the Convention, Estonia 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.

25-11-2021

On 25 November 2021, as a Party to the Convention and pursuant to Article 35(7)(b) of the Convention, Estonia 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: Austria, Cyprus, Finland, Latvia, Poland, Slovakia and Ukraine.
The provisions of the Convention will enter into effect for the listed agreements in accordance with Article 35(1) as modified by Article 35(7)(a).
Pursuant to Article 35(7)(b) of the Convention, the Depositary hereby notifies the other Contracting Jurisdictions on behalf of Estonia and upon its request.
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.

01-06-2022

On 1 June 2022, as a Party to the Convention and pursuant to Article 35(7)(b) of the Convention, Estonia 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: Belgium, Georgia, India, Isle of Man, Lithuania, Norway and Spain.
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.

Eswatini

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.

Finland

25-02-2019

Pursuant to Articles 28(5) and Article 29(1) of the Convention, Finland deposited its list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.

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.

Frankrijk

26-09-2018

Pursuant to Articles 28(6) and Article 29(3) of the Convention, France deposited its list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.

22-09-2020

a) Pursuant to Article 29(5) of the Convention, France extends the list of agreements notified under Article 2(1)(a)(ii); and
b) Pursuant to Articles 29(5) and 29(6) of the Convention, France makes additional notifications under Articles 6(5), 6(6), 7(17), 8(4), 9(7), 12(5), 12(6), 13(7), 16(6) and 17(4).
The Consolidated MLI Position reflecting the updated list of reservations and notifications is also accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.

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.

Georgië

29-03-2019

Pursuant to Articles 28(5) and Article 29(1) of the Convention, Georgia deposited its list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.

02-12-2025

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.

Griekenland

30-03-2021

Pursuant to Articles 28(5) and 29(1) of the Convention, Greece 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.

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

Hongarije

25-03-2021

Pursuant to Articles 28(5) and 29(1) of the Convention, Hungary 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.

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

Ierland

29-01-2019

Pursuant to Articles 28(5) and 29(1) of the Convention, Ireland deposited its list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.

IJsland

26-09-2019

Pursuant to Articles 28(6) and Article 29(3) of the Convention, Iceland deposited its list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.

14-12-2021

a) Pursuant to Article 29(5) of the Convention, Iceland extends the list of agreements notified under Article 2(1)(a)(ii) of the Convention,
b) Pursuant to Article 29(5) of the Convention, Iceland specifies that the additional agreement notified is falling within the scope of its reservation under Article 17(3) of the Convention,
c) Pursuant to Articles 29(5) and 29(6) of the Convention, Iceland makes additional notifications under Articles 6(5) and 16(6) of the Convention,
The Consolidated MLI Position of Iceland reflecting its updated list of reservations and notifications is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.

India

25-06-2019

Pursuant to Articles 28(5) and Article 29(1) of the Convention, India deposited its list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.

Indonesië

28-04-2020

Pursuant to Articles 28(5) and 29(1) of the Convention, Indonesia deposited its list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.

26-11-2020

On 26 November 2020, 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: Australia, Canada, France, India, Japan, Luxembourg, Netherlands, New Zealand, Singapore, Republic of Korea, United Kingdom, United Arab Emirates, Belgium, Finland, Poland, Qatar, Slovak Republic, Denmark, Portugal, Russia, Serbia and Sweden.
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.

21-10-2021

On 21 October 2021, 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: Malaysia, Croatia, Egypt, Hungary and Pakistan.
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.

10-11-2022

On 10 November 2022, 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: People’s Republic of China, Hong Kong (China), Seychelles, Thailand, Romania and Spain. 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.

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.

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.

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

Israël

13-09-2018

Pursuant to Articles 28(6) and Article 29(3) of the Convention, Israel deposited its list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.

Ivoorkust

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.

Japan

20-09-2018

Pursuant to Articles 28(5) and Article 29(1) of the Convention, Japan deposited its list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.

14-02-2020

On 14 February 2020, as a Party to the Convention, Japan notified the Depositary of the following:
a) Pursuant to Article 29(5) of the Convention, Japan extends the list of agreements notified under Article 2(1)(a)(ii); and
b) Pursuant to Article 29(5) of the Convention, Japan makes additional notifications under Articles 4(4), 6(5), 6(6), 7(17)(a), 9(7), 12(5), 12(6), 13(7), 16(6)(a), 16(6)(b)(ii) and 17(4)
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.

22-07-2020

Pursuant to Article 29(5) of the Convention, Japan extends the list of agreements notified under Article 2(1)(a)(ii) and pursuant to Article 29(5) of the Convention, Japan makes additional notifications under Articles 4(4), 6(5), 6(6), 7(17)(a), 9(7), 12(5), 12(6), 13(7), 16(6)(a), 16(6)(b)(ii) and 17(4). 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.

21-04-2022

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), 12(5), 12(6), 13(7), 16(6)(a), 16(6)(b)(ii), 16(6)(c)(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.

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.

Jordanië

29-09-2020

Pursuant to Articles 28(5) and 29(1) of the Convention, Jordan deposited its list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.

Kameroen

21-04-2022

Pursuant to Articles 28(5) and 29(1) of the Convention, Cameroon 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.

Kazachstan

24-06-2020

Pursuant to Articles 28(5) and 29(1) of the Convention, Kazakhstan deposited its list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.

26-11-2020

Pursuant to Article 29(6) of the Convention, Kazakhstan makes additional notifications under Articles 6(5), 7(17)(a), 9(7), 14(4), 16(6)(a) and 17(4) of the Convention.
The Consolidated MLI Position reflecting the updated list of notifications is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.

Kenia

26-11-2019

Pursuant to Articles 28(7) and 29(4) of the Convention, Kenya 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.

08-01-2025

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.

Kroatië

18-02-2021

Pursuant to Articles 28(6) and 29(3) of the Convention, Croatia deposited its list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.

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.

Lesotho

28-07-2022

Pursuant to Articles 28(5) and 29(1) of the Convention, Lesotho 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.

Letland

29-10-2019

Pursuant to Articles 28(5) and Article 29(1) of the Convention, Latvia deposited its list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.

20-04-2021

a) Pursuant to Article 29(5) of the Convention, Latvia extends the list of agreements notified under Article 2(1)(a)(ii) of the Convention,
b) Latvia notifies the date of entry into force of an amending instrument included in the list of agreements previously notified under Article 2(1)(a)(ii) of the Convention,
c) Pursuant to Articles 29(5) of the Convention, Latvia makes an additional notification under Article 16(6)(b)(ii) of the Convention.
d) Pursuant to Article 29(5) of the Convention, Latvia specifies the additional agreement falling within the scope of its reservation under Article 17(3)(a) 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.

Liechtenstein

19-12-2019

Pursuant to Articles 28(5) and Article 29(1) of the Convention, Liechtenstein deposited its list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.

Litouwen

11-09-2018

Pursuant to Articles 28(5) and Article 29(1) of the Convention, Lithuania deposited its list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.

Luxemburg

09-04-2019

Pursuant to Articles 28(6) and Article 29(3) of the Convention, Luxemburg deposited its list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.

Maleisië

18-02-2021

Pursuant to Articles 28(5) and 29(1) of the Convention, Malaysia deposited its list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.

10-11-2022

On 10 November 2022, as a Party to the Convention, Malaysia notified the Depositary of the following:
a) Pursuant to Article 29(5) of the Convention, Malaysia extends the list of agreements notified under Article 2(1)(a)(ii) of the Convention;
b) Pursuant to Article 29(5) of the Convention, Malaysia specifies the additional agreement falling within the scope of its reservations under Article 17(3)(a) of the Convention,
c) Pursuant to Article 29(5) of the Convention, Malaysia makes additional notifications under Articles 6(5), 7(17)(a), 12(5), 12(6), 13(7), 16(6)(a), 16(6)(b)(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.

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.

Malta

18-12-2018

Pursuant to Articles 28(6) and Article 29(3) of the Convention, Malta deposited its list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.

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

Marokko

25-06-2019

Pursuant to Articles 28(7) and Article 29(4) of the Convention, Morocco deposited its 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.

Mauritius

18-10-2019

Pursuant to Articles 28(5) and Article 29(1) of the Convention, Mauritius deposited its list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.

Mexico

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.

Monaco

10-01-2019

Pursuant to Articles 28(6) and Article 29(3) of the Convention, Monaco deposited its list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.

Mongolië

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

Montenegro

12-11-2025

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.

Namibië

30-09-2021

At the time of signature, pursuant to Articles 28(7) and 29(4) of the Convention, Namibia 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.

Nederlanden, het Koninkrijk der

29-03-2019

Pursuant to Articles 28(4), 28(5), 29(1) and 29(2) of the Convention, The Netherlands deposited its list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf

29-03-2019

Pursuant to Articles 28(4), 28(5), 29(1) and 29(2) of the Convention, Curaçao deposited its list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf

25-11-2021

a) Pursuant to Article 29(5) of the Convention, the Netherlands extends the list of agreements notified under Article 2(1)(a)(ii) of the Convention,
b) Pursuant to Article 29(5) of the Convention, the Netherlands specifies the additional agreement falling within the scope of its reservation under Article 14(3) of the Convention,
c) Pursuant to Article 29(5) of the Convention, the Netherlands makes additional notifications under Articles 3(6), 4(4), 5(10), 6(5) and (6), 8(4), 13(7), 16(6), and 17(4) of the Convention,
d) Pursuant to Article 35(5)(b) of the Convention, the Netherlands notifies that it intends to apply a shorter period with respect to the following agreement: the Convention between the Kingdom of the Netherlands and the Kingdom of Belgium for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital: one calendar month and six days.
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.

Nieuw-Zeeland

27-06-2018

Pursuant to Articles 28(5) and 29(1) of the Convention, New Zealand deposited its list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.

New Zealand declared that its ratification shall not extend to Tokelau unless and until a declaration to this effect is lodged by the Government of New Zealand with the Depositary.

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.

Noord-Macedonië

29-01-2020

Pursuant to Articles 28(6) and Article 29(3) of the Convention, North Macedonia deposited its 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.

Noorwegen

17-07-2019

Pursuant to Articles 28(5) and Article 29(1) of the Convention, Norway deposited its list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.

Oekraïne

08-08-2019

Pursuant to Articles 28(5) and Article 29(1) of the Convention, Ukraine deposited its list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.

20-10-2025

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.

Oman

07-07-2020

Pursuant to Articles 28(6) and 29(3) of the Convention, Oman deposited its list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.

Oostenrijk

22-09-2017

Pursuant to Articles 28(6) and Article 29(3) of the Convention, Austria deposited its list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.

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.

Pakistan

18-12-2020

Pursuant to Articles 28(5) and 29(1) of the Convention, Pakistan deposited its list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.

Panama

05-11-2020

Pursuant to Articles 28(5) and 29(1) of the Convention, Panama deposited its list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.

Papoea-Nieuw-Guinea

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.

Peru

09-06-2025

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

Polen

23-01-2018

Pursuant to Articles 28(6) and Article 29(3) of the Convention, Polen deposited its list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.

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.

Portugal

28-02-2020

Pursuant to Articles 28(5) and 29(1) of the Convention, Portugal deposited its list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.

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.

Qatar

23-12-2019

Pursuant to Articles 28(6) and Article 29(3) of the Convention, Qatar deposited its list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.

25-11-2021

a) Pursuant to Article 29(5) of the Convention, the State of Qatar extends the list of agreements notified under Article 2(1)(a)(ii) of the Convention,
b) Pursuant to Article 29(5) of the Convention, the State of Qatar makes additional notifications under Articles 6(5)(6) and 16(6) of the Convention,
Qatar also notified corrections to the list of reservations and notifications deposited upon the deposit of its instrument of ratification of the Convention on 23 December 2019.
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.

Roemenië

28-02-2022

Pursuant to Articles 28(5) and 29(1) of the Convention, Romania 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.

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.

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.

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.

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.

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.

10-01-2025

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.

Russische Federatie

25-06-2019

Pursuant to Articles 28(5) and Article 29(1) of the Convention, the Russian Federation deposited its list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.

30-04-2020

Pursuant to Article 35(7)(b) of the Convention, the Russian Federation notified in relation to Article 35(7)(a)(i) of the Convention 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:
Australia, Austria, Belgium (old), Canada, Denmark, Finland, France, Iceland, India, Ireland, Israel, Latvia, Lithuania, Luxembourg, Malta, Netherlands, New Zealand, Norway, Poland, Qatar, Serbia, Singapore, Slovak Republic, Slovenia, Ukraine, United Arab Emirates, United Kingdom.
The provisions of the Convention will enter into effect for the listed agreements in accordance with the provisions of Article 35(1) as modified by Article 35(7)(a).
Pursuant to Article 35(7)(b) of the Convention, the Depositary hereby notifies the other Contracting Jurisdictions on behalf of the Russian Federation and upon its request.
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.

26-11-2020

On 26 November 2020, 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: Cyprus, Czech Republic, Indonesia, Kazakhstan, Korea, Portugal and Saudi Arabia.
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.

21-10-2021

On 21 October 2021, 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: Albania, Chile, Croatia, Egypt, Greece, Hungary, and Malaysia.
On 21 October 2021, as a Party to the Convention and pursuant to Article 35(7)(b) of the Convention, the Russian Federation also 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 their agreement: Kazakhstan.
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.

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.

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.

San Marino

11-03-2020

Pursuant to Articles 28(5) and 29(1) of the Convention, San Marino deposited its list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.

Saudi-Arabië

23-01-2020

Pursuant to Articles 28(5) and Article 29(1) of the Convention, Saudi Arabia deposited its list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.

Senegal

10-05-2022

Pursuant to Articles 28(5) and 29(1) of the Convention, Senegal 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.

Servië

05-06-2018

Pursuant to Articles 28(6) and 29(3) of the Convention, Serbia deposited its list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf

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.

Seychellen

14-12-2021

Pursuant to Articles 28(5) and 29(1) of the Convention, the Seychelles 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.

Singapore

21-12-2018

Pursuant to Articles 28(5) and 29(1) of the Convention, Singapore deposited its list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.

Slovenië

22-03-2018

Pursuant to Articles 28(5) and Article 29(1) of the Convention, Slovenia deposited its list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.

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.

Slowakije

26-09-2018

Pursuant to Articles 28(6) and Article 29(3) of the Convention, Slovakia deposited its list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.

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

Spanje

07-06-2017

In the event that the present Convention were to be extended to the British Overseas Territory of Gibraltar or to be signed by its authorities, Spain wishes to make the following declaration:
1. Gibraltar is a non‐autonomous territory for the international relations of which the United Kingdom is responsible and which is subject to a decolonization process in accordance with the relevant decisions and resolutions of the General Assembly of the United Nations.
2. The authorities of Gibraltar are of a local nature and exercise exclusively internal competences which have their origin and their foundation in the distribution and attribution of competences performed by the United Kingdom, in compliance with its internal legislation, in its capacity as sovereign State on which the mentioned non‐autonomous territory depends.
3. As a result, should the Gibraltarian authorities participate in the application of this Agreement it will be understood as effected exclusively within the scope of the internal competences of Gibraltar, and it cannot be considered to produce any change whatsoever in relation with what was established in the two preceding paragraphs.
4. The procedure established by the Regime relating to Gibraltar authorities in the context of certain international treaties agreed upon by Spain and the United Kingdom on 19 December 2007 (together with the “Agreed arrangements relating to Gibraltar authorities in the context of the European Union and European Community instruments and related Treaties of 19th April 2000”) is applicable to this Convention.
5. The application to Gibraltar of the present Convention cannot be interpreted as recognition of any rights or situations involving matters not included in Article 10 of the Treaty of Utrecht of 13 July 1713, signed by the crowns of Spain and Great Britain.

28-09-2021

Pursuant to Articles 28(5) and 29(1) of the Convention, Spain 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.

01-06-2022

On 1 June 2022, 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: Albania, Germany, Andorra, Saudi Arabia, Australia, Austria, Barbados, Belgium, Bosnia and Herzegovina, Canada, Qatar, Czech Republic, Chile, Cyprus, Korea, Costa Rica, Croatia, Egypt, United Arab Emirates, Slovak Republic, Slovenia, Estonia, Finland, France, Georgia, Greece, Hungary, Indonesia, Ireland, Iceland, Israel, Kazakhstan, Latvia, Lithuania, Luxembourg, Malaysia, Malta, New Zealand, Oman, Pakistan, Panama, Poland, Portugal, United Kingdom, Russia, Serbia, Singapore, Uruguay, India and Romania.
On 1 June 2022, as a Party to the Convention and pursuant to Article 35(7)(b) and 36 of the Convention, Spain 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: Germany, Andorra, Australia, Austria, Barbados, Belgium, Canada, Slovenia, Finland, France, Greece, Hungary, Ireland, Luxembourg, Malta, New Zealand, Portugal, United Kingdom and Singapore.
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.

30-11-2022

On 30 November 2022, 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: Hong Kong (China), Senegal and Thailand. The notifications made pursuant to Article 35(7)(b) are accessibile on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.

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.

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.

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.

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

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 .

Thailand

31-03-2022

Pursuant to Articles 28(5) and 29(1) of the Convention, Thailand 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.

Tsjechië

13-05-2020

Pursuant to Articles 28(5) and 29(1) of the Convention, the Czech Republic deposited its list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.

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.

Tunesië

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.

Turkije

07-06-2017

The Republic of Turkey declares that it will implement the provisions of Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting-MLI only to the States Parties with which it has diplomatic relations.
Turkey's signature of this Convention should in no way be construed as the recognition of the so-called "Republic of Cyprus" by Turkey, nor should it imply any obligation on the part of Turkey to enter into any dealing with the so-called Republic of Cyprus within the framework of the said Convention.

Uruguay

06-02-2020

Pursuant to Articles 28(6) and Article 29(3) of the Convention, Uruguay deposited its list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.

Verenigd Koninkrijk

25-10-2017

Pursuant to Articles 28(5) and Article 29(1) of the Convention, the Isle of Man deposited its list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.

15-12-2017

Pursuant to Articles 28(5) and Article 29(1) of the Convention, Jersey deposited its list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.

29-06-2018

Pursuant to Articles 28(5) and 29(1) of the Convention, the United Kingdom deposited its list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.

12-02-2019

Pursuant to Articles 28(5) and Article 29(1) of the Convention, Guernsey deposited its list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.

Verenigde Arabische Emiraten

29-05-2019

Pursuant to Articles 28(5) and Article 29(1) of the Convention, United Arab Emirates deposited its list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.

Vietnam

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.

Zuid-Afrika

30-09-2022

Pursuant to Articles 28(6) and 29(3) of the Convention, South Africa 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.

Zuid-Korea

13-05-2020

Pursuant to Articles 28(5) and 29(1) of the Convention, Korea deposited its list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.

Zweden

22-06-2018

Pursuant to Articles 28(6) and 29(3) of the Convention, Sweden deposited its list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.

Zwitserland

29-08-2019

Pursuant to Articles 28(6) and Article 29(3) of the Convention, Switzerland deposited its list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.

27-05-2020

Pursuant to Article 35(7)(b) of the Convention, Switzerland notified in relation to Article 35(7)(a)(i) of the Convention 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: Luxembourg.
The provisions of the Convention will enter into effect for the listed agreement in accordance with the provisions of Article 35(1) as modified by Article 35(7)(a).
Pursuant to Article 35(7)(b) of the Convention, Switzerland notifies the other Contracting Jurisdiction.
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.

18-12-2020

On 18 December 2020, 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 agreements: Lithuania and the Czech Republic.
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.

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.