This makes Brazil the 106th jurisdiction to join the landmark agreement to strengthen tax treaties, which now covers around 2,000 bilateral tax treaties.
The OECD has announced that Brazil signed the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (the BEPS Convention) at a signing ceremony held in Paris on 20 October 2025.
This makes Brazil the 106th jurisdiction to join the agreement to strengthen tax treaties, which now covers around 2,000 bilateral tax treaties. This represents an important milestone in the implementation of treaty-related BEPS measures and the strengthening of the global tax treaty network.
At the time of writing, 90 jurisdictions have either ratified, accepted, or approved the BEPS Convention, resulting in the modification of over 1,600 treaties. Around 400 additional treaties will be modified once the BEPS Convention will have been ratified by all Signatories.
The BEPS Convention, negotiated by more than 100 countries and jurisdictions under a mandate from the G20 Finance Ministers and Central Bank Governors, is one of the most prominent results of the OECD/G20 BEPS Project. It is the world’s leading instrument for updating bilateral tax treaties and reducing opportunities for tax avoidance by multinational enterprises. Measures included in the BEPS Convention address treaty abuse, strategies to avoid the creation of a “permanent establishment”, and hybrid mismatch arrangements. The BEPS Convention also enhances the dispute resolution mechanism, especially through the addition of an optional provision on mandatory binding arbitration, which has been taken up by 34 jurisdictions.
The OECD also released Brazil’s provisional Reservations and Notifications statement on the same day.
