Finland updated its position under the OECD’s Multilateral Instrument, correcting references in its 1996 tax treaty with Brazil to ensure accurate application of the Mutual Agreement Procedure.
Finland submitted an updated consolidated position for the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI), as noted by the OECD on 11 December 2025.
This update includes two specific corrections regarding Finland’s 1996 tax treaty with Brazil and the application of MLI Article 16, which governs the Mutual Agreement Procedure (MAP). In the original submission, references to Article 26 of the treaty were mistakenly made; they have now been corrected to refer to Article 24.
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.
