On 9 December 2020, Namibia deposited its ratification instrument for the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI).  The MLI will enter into force for Namibia on 1 April 2021 and will generally apply from 1 January 2022, although it may apply for earlier periods between signatories if agreed to and applies in relation to any period regarding criminal matters.