On 1 January 2019, the Multilateral Convention to Implement Tax Treaty-Related Measures to Prevent BEPS (‘Multilateral Instrument’ or ‘MLI’) entered into force in respect of Japan. The MLI was signed by Japan on 7 June 2017.
As of 1 October 2018, 84 jurisdictions have signed the MLI, of which 15 jurisdictions have deposited the instrument of ratification with the OECD. The instrument of ratification, approval or acceptance imports the provisions of the MLI into the domestic law of the signatory, and dictates when the MLI will enter into force in that jurisdiction.
The MLI was approved by the Diet on 18 May 2018, and Japan’s instrument of acceptance of the MLI was deposited on 26 September 2018, making Japan the 13th jurisdiction to deposit its instrument of acceptance. The number of Japanese CTA, notified upon the deposit of the instrument of acceptance, increased from 35 (as notified at the point of signing the MLI) to 39.
