Switzerland has notified the OECD that it has completed the domestic procedures required for the Multilateral Instrument (MLI) to take effect for its tax treaty with Argentina, paving the way for the treaty changes to apply from 1 January 2027.
Switzerland has completed the domestic steps required for the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) to take effect for its covered tax treaty with Argentina, according to an OECD update.
On 28 May 2026, Switzerland deposited a notification confirming the completion of its internal procedures for the entry into effect of the MLI with respect to its tax treaty with Argentina. The notification was required because Switzerland has reserved the right for the MLI to become effective only after such confirmation has been formally deposited.
As a result, the MLI provisions will generally apply to the Switzerland–Argentina treaty from 1 January 2027 for taxes withheld at source. For all other taxes, the MLI will apply from 1 January 2027 in Argentina and from 27 December 2026 in Switzerland.
Switzerland signed the MLI on 7 June 2017, and the Convention entered into force for the country on 1 December 2019. The Argentina notification is the latest submitted by Switzerland under Article 35, paragraph 7, letter b, following similar notifications for Luxembourg, Lithuania, Czechia and Iceland.
The MLI is a key element of the OECD/G20 BEPS project and, as of 18 June 2026, includes 107 jurisdictions. The Convention enables participating jurisdictions to update bilateral tax treaties with measures designed to prevent Base Erosion and Profit Shifting and address treaty-related tax avoidance.
