The OECD announced on 16 November 2018 that new guidance is available for the development of synthesised texts presenting a clear overview of the modifications by countries to their bilateral double tax treaties as a result of applying the Multilateral Convention (MLI) to implement tax treaty related measures to prevent base erosion and profit shifting (BEPS). The MLI entered into force on 1 July 2018 following completion and submission of necessary ratifications by signatory countries.
The MLI aims to modify the bilateral tax treaties to quickly implement BEPS treaty related measures including provisions developed under Action 2 on hybrid mismatch arrangements; Action 6 on preventing the granting of treaty benefits in inappropriate circumstances; Action 7 on preventing the artificial avoidance of permanent establishment (PE) status; and the measures on minimum standards ad best practices under Action 14 to make dispute resolution procedures more effective.
A Secretariat note was also released by the OECD, clarifying the entry into effect rules for the tax treaties of jurisdictions that deposited their MLI ratification instruments in September 2018.
