Finland announced that the MLI will apply to its 1994 tax treaty with Argentina starting 1 January 2026.
Finland issued Notice 51/2025 on 3 November 2025, announcing that the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) will enter into force for its 1994 income and capital tax treaty with Argentina.
The MLI is set to enter into force on 1 January 2026.
Earlier, on 29 September 2025, Argentina deposited its instrument of commitment, along with associated reservations and notifications, with the Secretary-General of the OECD, the depositary of the Convention. The Secretary-General maintains publicly accessible information on tax agreements covered by the Convention, as well as the reservations and notifications submitted by Parties on the OECD’s external website.
The MLI is set to take effect in Argentina starting 1 January 2026. However, its application to Argentina’s individual tax treaties will depend on whether the other countries involved in those agreements have also ratified the MLI.
The Multilateral Instrument (BEPS MLI) offers concrete solutions for governments to close loopholes in international tax treaties by transposing results from the BEPS Project into bilateral tax treaties worldwide. The BEPS MLI allows governments to implement agreed minimum standards to counter treaty abuse and to improve dispute resolution mechanisms while providing flexibility to accommodate specific tax treaty policies.
