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Download XMLMultilateraal Verdrag ter implementatie van aan belastingverdragen gerelateerde maatregelen ter voorkoming van grondslaguitholling en winstverschuiving
Partijen met voorbehouden, verklaringen en bezwaren
Albanië
22-09-2020
Pursuant to Articles 28(5) and 29(1) of the Convention, Albania deposited its list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
Algerije
27-06-2024
At the time of signature, pursuant to Articles 28(7) and 29(4) of the Convention, Algeria provided a list of expected reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
Andorra
29-09-2021
Pursuant to Articles 28(5) and 29(1) of the Convention, Andorra deposited a list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
Armenië
25-09-2023
Pursuant to Articles 28(6) and 29(3)of the Convention, Armenia deposited a list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
Australië
26-09-2018
Pursuant to Articles 28(5) and Article 29(1) of the Convention, Australia deposited its list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
Azerbeidzjan
24-09-2024
Pursuant to Articles 28(5) and 29(1) of the Convention, Azerbaijan deposited a list of reservations and notifications which is also accessible on the OECD website: https://www.oecd.org/content/dam/oecd/en/topics/policy-sub-issues/beps-mli/beps-mli-signatories-and-parties.pdf
Bahrein
23-02-2022
Pursuant to Articles 28(5) and 29(1) of the Convention, Bahrain deposited a list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
Barbados
21-12-2020
Pursuant to Articles 28(5) and 29(1) of the Convention, Barbados deposited a list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
België
26-06-2019
Pursuant to Articles 28(6) and Article 29(3) of the Convention, Belgium deposited its list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
25-11-2021
Pursuant to paragraphs 1(b) and (5)(b) of Article 35 of the Convention, the Kingdom
of Belgium notifies that it intends to apply a shorter period with respect to the
following agreement: the Convention between the Kingdom of the Netherlands and the
Kingdom of Belgium for the avoidance of double taxation and the prevention of fiscal
evasion with respect to taxes on income and on capital: one calendar month and six
days.
The Consolidated MLI Position reflecting the updated list of reservations and notifications
is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
Belize
07-04-2022
Pursuant to Articles 28(5) and 29(1) of the Convention, Belize deposited a list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
Bosnië en Herzegovina
16-09-2020
Pursuant to Articles 28(5) and 29(1) of the Convention, Bosnia and Herzegovina deposited its list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
Bulgarije
16-09-2022
Pursuant to Articles 28(5) and 29(1) of the Convention, Bulgaria deposited a list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
Burkina Faso
30-10-2020
Pursuant to Articles 28(5) and 29(1) of the Convention, Burkina Faso deposited its list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
Canada
29-08-2019
Pursuant to Articles 28(5) and Article 29(1) of the Convention, Canada deposited its list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
Chili
26-11-2020
Pursuant to Articles 28(6) and 29(3) of the Convention, Chile deposited its list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
China
25-05-2022
Pursuant to Articles 28(5) and 29(1) of the Convention, China deposited a list of reservations and notifications. Pursuant to Articles 28(4), 28(5), 29(1) and 29(2), China deposited a separate list of reservations in respect of Hong Kong (China). Both lists are accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
21-02-2023
On 21 February 2023, as a Party to the Convention and pursuant to Article 35(7)(b)
of the Convention, the People’s Republic of China on behalf of Hong Kong (China) notified
the confirmation of the completion of internal procedures for the entry into effect
of the provisions of the Convention with respect to the following agreements: Austria,
Belgium, Canada, Czech Republic, France, Guernsey, Hungary, India, Indonesia, Ireland,
Japan, Jersey, Korea, Latvia, Liechtenstein, Luxembourg, Malaysia, Malta, Netherlands,
New Zealand, Pakistan, Portugal, Qatar, Romania, Russian Federation, Saudi Arabia,
South Africa, Spain, Thailand, United Arab Emirates and United Kingdom.
The notifications made pursuant to Article 35(7)(b) are accessible on the OECD website:
http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
22-02-2024
On 22 February 2024, as a Party to the Convention and pursuant to Article 35(7)(b) of the Convention, the People’s Republic of China on behalf of Hong Kong (China) notified the confirmation of the completion of internal procedures for the entry into effect of the provisions of the Convention with respect to Hong Kong (China)’s following agreements: Mexico and Vietnam. The notifications made pursuant to Article 35(7)(b) are accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
Congo, Democratische Republiek
19-09-2024
At the time of signature, pursuant to Articles 28(7) and 29(4) of the Convention, the Democratic Republic of the Congo provided a list of expected reservations and notifications which is accessible on the OECD website: https://www.oecd.org/content/dam/oecd/en/topics/policy-sub-issues/beps-mli/beps-mli-signatories-and-parties.pdf
Costa Rica
22-09-2020
Pursuant to Articles 28(5) and 29(1) of the Convention, Costa Rica deposited its list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
Cyprus
23-01-2020
Pursuant to Articles 28(5) and Article 29(1) of the Convention, Cyprus deposited its list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
Denemarken
30-09-2019
Pursuant to Articles 28(5) and Article 29(1) of the Convention, Denmark deposited its list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
Duitsland
18-12-2020
Pursuant to Articles 28(5) and 29(1) of the Convention, Germany deposited its list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
02-10-2024
A. Notification by Germany under Article 35(7)(a)(i)
On 2 October 2024, as a Party to the Convention and pursuant to Article 35(7)(b) of
the Convention, Germany notified the confirmation of the completion of its internal
procedures for the entry into effect of the provisions of the Convention with respect
to the following agreements: Croatia, France, Greece, Hungary, Malta, Slovak Republic,
Spain.
B. Notification by Germany under Article 35(7)(a)(vii)
On 2 October 2024, as a Party to the Convention and pursuant to Article 35(7)(b) and
36 of the Convention, Germany notified the confirmation of the completion of its internal
procedures for the entry into effect of the provisions of Part VI of the Convention
(Arbitration) with respect to the following agreements: Greece, Hungary, Malta, Spain.
Pursuant to Article 35(7)(b) of the Convention, the Depositary hereby notifies the
other Contracting Jurisdictions on behalf of Germany. The notifications made pursuant
to Article 35(7)(b) are accessible on the OECD website: https://www.oecd.org/content/dam/oecd/en/topics/policy-sub-issues/beps-mli/beps-mli-signatories-and-parties.pdf
02-10-2024
Pursuant to Article 35(1)(b) of the Convention, Germany notified that it intends to
apply a shorter period than six calendar months with respect to the following agreements:
Croatia, 2 calendar months; France, 2 calendar months; Greece, 2 calendar months;
Hungary, 2 calendar months; Malta, 2 calendar months; Slovak Republic, 2 calendar
months; Spain, 2 calendar months. The notifications are accessible on the OECD website:
https://www.oecd.org/content/dam/oecd/en/topics/policy-sub-issues/beps-mli/beps-mli-signatories-and-parties.pdf
Egypte
30-09-2020
Pursuant to Articles 28(6) and 29(3) of the Convention, Egypt deposited its list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
Estland
15-01-2021
Pursuant to Articles 28(6) and 29(3) of the Convention, Estonia deposited a list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
25-11-2021
On 25 November 2021, as a Party to the Convention and pursuant to Article 35(7)(b)
of the Convention, Estonia notified the confirmation of the completion of its internal
procedures for the entry into effect of the provisions of the Convention with respect
to the following agreements: Austria, Cyprus, Finland, Latvia, Poland, Slovakia and
Ukraine.
The provisions of the Convention will enter into effect for the listed agreements
in accordance with Article 35(1) as modified by Article 35(7)(a).
Pursuant to Article 35(7)(b) of the Convention, the Depositary hereby notifies the
other Contracting Jurisdictions on behalf of Estonia and upon its request.
The notifications made pursuant to Article 35(7)(b) are accessible on the OECD website:
http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
01-06-2022
On 1 June 2022, as a Party to the Convention and pursuant to Article 35(7)(b) of the
Convention, Estonia notified the confirmation of the completion of its internal procedures
for the entry into effect of the provisions of the Convention with respect to the
following agreements: Belgium, Georgia, India, Isle of Man, Lithuania, Norway and
Spain.
The notifications made pursuant to Article 35(7)(b) are accessible on the OECD website:
http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
Eswatini
27-09-2023
At the time of signature, pursuant to Articles 28(7) and 29(4) of the Convention, Eswatini provided a list of expected reservations and notifications which is also accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
Finland
25-02-2019
Pursuant to Articles 28(5) and Article 29(1) of the Convention, Finland deposited its list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
27-06-2023
Pursuant to Article 29(6) of the Convention, Finland makes additional notifications
under Article 9(7) and (8) of the Convention.
Pursuant to Article 28(9) of the Convention, Finland withdraws the reservation made
under Article 9(6) of the Convention.
The Consolidated MLI Position reflecting the updated list of reservations and notifications
is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
Frankrijk
26-09-2018
Pursuant to Articles 28(6) and Article 29(3) of the Convention, France deposited its list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
22-09-2020
a) Pursuant to Article 29(5) of the Convention, France extends the list of
agreements notified under Article 2(1)(a)(ii); and
b) Pursuant to Articles 29(5) and 29(6) of the Convention, France makes additional
notifications under Articles 6(5), 6(6), 7(17), 8(4), 9(7), 12(5), 12(6), 13(7),
16(6) and 17(4).
The Consolidated MLI Position reflecting the updated list of reservations and notifications
is also accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
13-11-2024
Pursuant to Article 35(1)(b) of the Convention, France notified that it intends to apply a shorter period than six calendar months with respect to the following agreement: Germany, 2 calendar months. The notification is accessible on the OECD website: https://www.oecd.org/content/dam/oecd/en/topics/policy-sub-issues/beps-mli/beps-mli-signatories-and-parties.pdf.
Georgië
29-03-2019
Pursuant to Articles 28(5) and Article 29(1) of the Convention, Georgia deposited its list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
Griekenland
30-03-2021
Pursuant to Articles 28(5) and 29(1) of the Convention, Greece deposited a list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
02-10-2024
Pursuant to Article 35(1)(b) of the Convention, Greece notified that it intends to
apply a shorter period than six calendar months with respect to its agreement with
Germany: 2 calendar months.
The notifications are accessible on the OECD website: https://www.oecd.org/content/dam/oecd/en/topics/policy-sub-issues/beps-mli/beps-mli-signatories-and-parties.pdf
Hongarije
25-03-2021
Pursuant to Articles 28(5) and 29(1) of the Convention, Hungary deposited a list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
02-10-2024
Pursuant to Article 35(1)(b) of the Convention, Hungary notified that it intends to
apply a shorter period than six calendar months with respect to their agreement with
Germany and that it intends to apply a period of two calendar months.
The notifications are accessible on the OECD website: https://www.oecd.org/content/dam/oecd/en/topics/policy-sub-issues/beps-mli/beps-mli-signatories-and-parties.pdf
Ierland
29-01-2019
Pursuant to Articles 28(5) and 29(1) of the Convention, Ireland deposited its list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
IJsland
26-09-2019
Pursuant to Articles 28(6) and Article 29(3) of the Convention, Iceland deposited its list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
14-12-2021
a) Pursuant to Article 29(5) of the Convention, Iceland extends the list of
agreements notified under Article 2(1)(a)(ii) of the Convention,
b) Pursuant to Article 29(5) of the Convention, Iceland specifies that the additional
agreement notified is falling within the scope of its reservation under Article 17(3)
of the Convention,
c) Pursuant to Articles 29(5) and 29(6) of the Convention, Iceland makes additional
notifications under Articles 6(5) and 16(6) of the Convention,
The Consolidated MLI Position of Iceland reflecting its updated list of reservations
and notifications is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
India
25-06-2019
Pursuant to Articles 28(5) and Article 29(1) of the Convention, India deposited its list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
Indonesië
28-04-2020
Pursuant to Articles 28(5) and 29(1) of the Convention, Indonesia deposited its list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
26-11-2020
On 26 November 2020, as a Party to the Convention and pursuant to Article 35(7)(b)
of the Convention, Indonesia notified the confirmation of the completion of its internal
procedures for the entry into effect of the provisions of the Convention with respect
to the following agreements: Australia, Canada, France, India, Japan, Luxembourg,
Netherlands, New Zealand, Singapore, Republic of Korea, United Kingdom, United Arab
Emirates, Belgium, Finland, Poland, Qatar, Slovak Republic, Denmark, Portugal, Russia,
Serbia and Sweden.
The notifications made pursuant to Article 35(7)(b) are accessible on the OECD website:
http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
21-10-2021
On 21 October 2021, as a Party to the Convention and pursuant to Article 35(7)(b)
of the Convention, Indonesia notified the confirmation of the completion of its internal
procedures for the entry into effect of the provisions of the Convention with respect
to the following agreements: Malaysia, Croatia, Egypt, Hungary and Pakistan.
The notifications made pursuant to Article 35(7)(b) are accessible on the OECD website:
http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
10-11-2022
On 10 November 2022, as a Party to the Convention and pursuant to Article 35(7)(b) of the Convention, Indonesia notified the confirmation of the completion of its internal procedures for the entry into effect of the provisions of the Convention with respect to the following agreements: People’s Republic of China, Hong Kong (China), Seychelles, Thailand, Romania and Spain. The notifications made pursuant to Article 35(7)(b) are accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
27-11-2023
On 27 November 2023, as a Party to the Convention, Indonesia notified the Depositary
of the following:
a) Pursuant to Article 29(5) of the Convention, Indonesia extends the list of agreements
notified under Article 2(1)(a)(ii) of the Convention,
b) Pursuant to Articles 29(5) and 29(6) of the Convention, Indonesia makes additional
notifications under Articles 4(4), 6(5), 7(17), 8(4), 9(7), 11(4), 12(5)(6), 13(7),
16(6) and 17(4) of the Convention.
The Consolidated MLI Position reflecting the updated list of reservations and notifications
is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
27-11-2023
On 27 November 2023, as a Party to the Convention and pursuant to Article 35(7)(b)
of the Convention, Indonesia notified the confirmation of the completion of its internal
procedures for the entry into effect of the provisions of the Convention with respect
to the following agreements: Vietnam, South Africa, Bulgaria and Mexico.
On 27 November 2023, as a Party to the Convention and pursuant to Article 35(7)(b)
of the Convention, Indonesia notified the confirmation of the completion of its internal
procedures for the entry into effect of the withdrawal of a reservation made by the
following Party with respect to their agreement: Finland.
On 27 November 2023, as a Party to the Convention and pursuant to Article 35(7)(b)
of the Convention, Indonesia notified the confirmation of the completion of its internal
procedures for the entry into effect of the additional notification made by the following
Party with respect to their agreement: Finland.
The notifications made pursuant to Article 35(7)(b) are also accessible on the OECD
website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
29-10-2024
On 29 October 2024, as a Party to the Convention and pursuant to Article 35(7)(b)
of the Convention, Indonesia notified the confirmation of the completion of its internal
procedures for the entry into effect of the provisions of the Convention with respect
to the following agreement: Armenia.
On 29 October 2024, as a Party to the Convention and pursuant to Article 35(7)(b)
of the Convention, Indonesia notified the confirmation of the completion of its internal
procedures for the entry into effect of the provisions of the Convention with respect
to the following agreements resulting from an extension pursuant to Article 29(5)
of the Convention of the list of agreements notified under Article 2(1)(a)(ii): Jordan,
Papua New Guinea, Tunisia and Ukraine.
Pursuant to Article 35(7)(b) of the Convention, the Depositary hereby notifies the
other Contracting Jurisdictions on behalf of Indonesia. The notifications made pursuant
to Article 35(7)(b) are accessible on the OECD website: https://www.oecd.org/content/dam/oecd/en/topics/policy-sub-issues/beps-mli/beps-mli-signatories-and-parties.pdf
Israël
13-09-2018
Pursuant to Articles 28(6) and Article 29(3) of the Convention, Israel deposited its list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
Ivoorkust
25-09-2023
Pursuant to Articles 28(6) and 29(3)of the Convention, Côte d’Ivoire deposited a list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
Japan
20-09-2018
Pursuant to Articles 28(5) and Article 29(1) of the Convention, Japan deposited its list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
14-02-2020
On 14 February 2020, as a Party to the Convention, Japan notified the Depositary of
the following:
a) Pursuant to Article 29(5) of the Convention, Japan extends the list of agreements
notified under Article 2(1)(a)(ii); and
b) Pursuant to Article 29(5) of the Convention, Japan makes additional notifications
under Articles 4(4), 6(5), 6(6), 7(17)(a), 9(7), 12(5), 12(6), 13(7), 16(6)(a), 16(6)(b)(ii)
and 17(4)
The Consolidated MLI Position reflecting the updated list of reservations and notifications
is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
22-07-2020
Pursuant to Article 29(5) of the Convention, Japan extends the list of agreements notified under Article 2(1)(a)(ii) and pursuant to Article 29(5) of the Convention, Japan makes additional notifications under Articles 4(4), 6(5), 6(6), 7(17)(a), 9(7), 12(5), 12(6), 13(7), 16(6)(a), 16(6)(b)(ii) and 17(4). The Consolidated MLI Position reflecting the updated list of reservations and notifications is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
21-04-2022
a) Pursuant to Article 29(5) of the Convention, Japan extends the list of
agreements notified under Article 2(1)(a)(ii) of the Convention; and
b) Pursuant to Article 29(5) of the Convention, Japan makes additional notifications
under Articles 4(4), 6(5), 6(6), 12(5), 12(6), 13(7), 16(6)(a), 16(6)(b)(ii), 16(6)(c)(ii)
and 17(4) of the Convention.
The Consolidated MLI Position reflecting the updated list of reservations and notifications
is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
20-06-2023
a) Pursuant to Article 29(5) of the Convention, Japan extends the list of agreements
notified under Article 2(1)(a)(ii) of the Convention; and
b) Pursuant to Article 29(5) of the Convention, Japan makes additional notifications
under Articles 4(4), 6(5), 6(6), 9(7), 12(5), 12(6), 13(7), 16(6)(a), 16(6)(b)(ii),
and 17(4) of the Convention.
The Consolidated MLI Position reflecting the updated list of reservations and notifications
is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
Jordanië
29-09-2020
Pursuant to Articles 28(5) and 29(1) of the Convention, Jordan deposited its list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
Kameroen
21-04-2022
Pursuant to Articles 28(5) and 29(1) of the Convention, Cameroon deposited a list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
Kazachstan
24-06-2020
Pursuant to Articles 28(5) and 29(1) of the Convention, Kazakhstan deposited its list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
26-11-2020
Pursuant to Article 29(6) of the Convention, Kazakhstan makes additional notifications
under Articles 6(5), 7(17)(a), 9(7), 14(4), 16(6)(a) and 17(4) of the Convention.
The Consolidated MLI Position reflecting the updated list of notifications is accessible
on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
Kenia
26-11-2019
Pursuant to Articles 28(7) and 29(4) of the Convention, Kenya provided a list of expected reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
Kroatië
18-02-2021
Pursuant to Articles 28(6) and 29(3) of the Convention, Croatia deposited its list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
02-10-2024
Pursuant to Article 35(1)(b) of the Convention, Croatia notified that it intends to
apply a shorter period than six calendar months with respect to the following agreement:
Germany; 2 calendar months.
Lesotho
28-07-2022
Pursuant to Articles 28(5) and 29(1) of the Convention, Lesotho deposited a list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
Letland
29-10-2019
Pursuant to Articles 28(5) and Article 29(1) of the Convention, Latvia deposited its list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
20-04-2021
a) Pursuant to Article 29(5) of the Convention, Latvia extends the list of agreements
notified under Article 2(1)(a)(ii) of the Convention,
b) Latvia notifies the date of entry into force of an amending instrument included
in the list of agreements previously notified under Article 2(1)(a)(ii) of the Convention,
c) Pursuant to Articles 29(5) of the Convention, Latvia makes an additional notification
under Article 16(6)(b)(ii) of the Convention.
d) Pursuant to Article 29(5) of the Convention, Latvia specifies the additional
agreement falling within the scope of its reservation under Article 17(3)(a) of the
Convention.
The Consolidated MLI Position reflecting the updated list of reservations and notifications
is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
Liechtenstein
19-12-2019
Pursuant to Articles 28(5) and Article 29(1) of the Convention, Liechtenstein deposited its list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
Litouwen
11-09-2018
Pursuant to Articles 28(5) and Article 29(1) of the Convention, Lithuania deposited its list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
Luxemburg
09-04-2019
Pursuant to Articles 28(6) and Article 29(3) of the Convention, Luxemburg deposited its list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
Maleisië
18-02-2021
Pursuant to Articles 28(5) and 29(1) of the Convention, Malaysia deposited its list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
10-11-2022
On 10 November 2022, as a Party to the Convention, Malaysia notified the Depositary
of the following:
a) Pursuant to Article 29(5) of the Convention, Malaysia extends the list of agreements
notified under Article 2(1)(a)(ii) of the Convention;
b) Pursuant to Article 29(5) of the Convention, Malaysia specifies the additional
agreement falling within the scope of its reservations under Article 17(3)(a) of the
Convention,
c) Pursuant to Article 29(5) of the Convention, Malaysia makes additional notifications
under Articles 6(5), 7(17)(a), 12(5), 12(6), 13(7), 16(6)(a), 16(6)(b)(ii) of the
Convention.
The Consolidated MLI Position reflecting the updated list of reservations and notifications
is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
28-11-2023
Pursuant to Article 35(5)(b) of the Convention and as a Party to the Convention, Malaysia notified that it intends to apply a shorter period of thirty days with respect to its agreement with Poland.
Malta
18-12-2018
Pursuant to Articles 28(6) and Article 29(3) of the Convention, Malta deposited its list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
02-10-2024
Pursuant to Article 35(1)(b) of the Convention, Malta notified that it intends to
apply a shorter period than six calendar months with respect to its agreement with
Germany and that it intends to apply a period of two calendar months.
The notifications are accessible on the OECD website: https://www.oecd.org/content/dam/oecd/en/topics/policy-sub-issues/beps-mli/beps-mli-signatories-and-parties.pdf
Marokko
25-06-2019
Pursuant to Articles 28(7) and Article 29(4) of the Convention, Morocco deposited its list of expected reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
Mauritius
18-10-2019
Pursuant to Articles 28(5) and Article 29(1) of the Convention, Mauritius deposited its list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
Mexico
15-03-2023
Pursuant to Articles 28(5) and 29(1) of the Convention, Mexico deposited a list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
Monaco
10-01-2019
Pursuant to Articles 28(6) and Article 29(3) of the Convention, Monaco deposited its list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
Mongolië
30-09-2024
Pursuant to Articles 28(5) and 29(1) of the Convention, Mongolia deposited a list of reservations and notifications which is also accessible on the OECD website: https://www.oecd.org/content/dam/oecd/en/topics/policy-sub-issues/beps-mli/beps-mli-signatories-and-parties.pdf
Namibië
30-09-2021
At the time of signature, pursuant to Articles 28(7) and 29(4) of the Convention, Namibia provided a list of expected reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
Nederlanden, het Koninkrijk der
29-03-2019
Pursuant to Articles 28(4), 28(5), 29(1) and 29(2) of the Convention, The Netherlands deposited its list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf
29-03-2019
Pursuant to Articles 28(4), 28(5), 29(1) and 29(2) of the Convention, Curaçao deposited its list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf
25-11-2021
a) Pursuant to Article 29(5) of the Convention, the Netherlands extends the list of
agreements notified under Article 2(1)(a)(ii) of the Convention,
b) Pursuant to Article 29(5) of the Convention, the Netherlands specifies the additional
agreement falling within the scope of its reservation under Article 14(3) of the Convention,
c) Pursuant to Article 29(5) of the Convention, the Netherlands makes additional notifications
under Articles 3(6), 4(4), 5(10), 6(5) and (6), 8(4), 13(7), 16(6), and 17(4) of the
Convention,
d) Pursuant to Article 35(5)(b) of the Convention, the Netherlands notifies that it
intends to apply a shorter period with respect to the following agreement: the Convention
between the Kingdom of the Netherlands and the Kingdom of Belgium for the avoidance
of double taxation and the prevention of fiscal evasion with respect to taxes on income
and on capital: one calendar month and six days.
The Consolidated MLI Position reflecting the updated list of reservations and notifications
is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
Nieuw-Zeeland
27-06-2018
Pursuant to Articles 28(5) and 29(1) of the Convention, New Zealand deposited its
list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
New Zealand declared that its ratification shall not extend to Tokelau unless and
until a declaration to this effect is lodged by the Government of New Zealand with
the Depositary.
20-06-2023
On 20 June 2023, as a Party to the Convention, New Zealand notified the Depositary
of two corrections to the list of reservations and notifications deposited by New
Zealand upon the deposit of its instrument of ratification of the Convention on 27
June 2018.
The corrected list of reservations and notifications made by New Zealand pursuant
to Articles 28(5) and 29(1) of the Convention is now available at http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
Noord-Macedonië
29-01-2020
Pursuant to Articles 28(6) and Article 29(3) of the Convention, North Macedonia deposited its list of expected reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
Noorwegen
17-07-2019
Pursuant to Articles 28(5) and Article 29(1) of the Convention, Norway deposited its list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
Oekraïne
08-08-2019
Pursuant to Articles 28(5) and Article 29(1) of the Convention, Ukraine deposited its list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
Oman
07-07-2020
Pursuant to Articles 28(6) and 29(3) of the Convention, Oman deposited its list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
Oostenrijk
22-09-2017
Pursuant to Articles 28(6) and Article 29(3) of the Convention, Austria deposited its list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
28-08-2023
On 28 August 2023, as a Party to the Convention, Austria notified the Depositary of
the following:
a) Pursuant to Article 29(5) of the Convention, Austria extends the list of agreements
notified under Article 2(1)(a)(ii) of the Convention,
b) Austria notifies the date of entry into force of an agreement and amending instruments
included in the list of agreements previously notified under Article 2(1)(a)(ii) of
the Convention,
c) Pursuant to Article 29(5) of the Convention Austria specifies the additional agreements
falling within the scope of its reservation under Article 26(4) of the Convention,
d) Pursuant to Articles 29(5) and 29(6) of the Convention Austria makes additional
notifications under Articles 5(10), 6(5), 13(7), 16(6) and 17(4) of the Convention.
The Consolidated MLI Position reflecting the updated list of reservations and notifications
is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
Pakistan
18-12-2020
Pursuant to Articles 28(5) and 29(1) of the Convention, Pakistan deposited its list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
Panama
05-11-2020
Pursuant to Articles 28(5) and 29(1) of the Convention, Panama deposited its list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
Papoea-Nieuw-Guinea
31-08-2023
Pursuant to Articles 28(5) and 29(1) of the Convention, Papua New Guinea deposited a list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
Polen
23-01-2018
Pursuant to Articles 28(6) and Article 29(3) of the Convention, Polen deposited its list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
28-11-2023
Pursuant to Article 35(5)(b) of the Convention and as a Party to the Convention, Poland notified that it intends to apply a shorter period of thirty days with respect to its agreement with Malaysia.
Portugal
28-02-2020
Pursuant to Articles 28(5) and 29(1) of the Convention, Portugal deposited its list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
06-03-2023
On 6 March 2023, as a Party to the Convention and pursuant to Article 29(5) of the
Convention, Portugal notified the Depositary of the date of entry into force of an
agreement included in the list of agreements previously notified under Article 2(1)(a)(ii)
of the Convention.
The Consolidated MLI Position reflecting the updated list of reservations and notifications
is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
Qatar
23-12-2019
Pursuant to Articles 28(6) and Article 29(3) of the Convention, Qatar deposited its list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
25-11-2021
a) Pursuant to Article 29(5) of the Convention, the State of Qatar extends the list
of agreements notified under Article 2(1)(a)(ii) of the Convention,
b) Pursuant to Article 29(5) of the Convention, the State of Qatar makes additional
notifications under Articles 6(5)(6) and 16(6) of the Convention,
Qatar also notified corrections to the list of reservations and notifications deposited
upon the deposit of its instrument of ratification of the Convention on 23 December
2019.
The Consolidated MLI Position reflecting the updated list of reservations and notifications
is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
Roemenië
28-02-2022
Pursuant to Articles 28(5) and 29(1) of the Convention, Romania deposited a list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
06-03-2023
On 6 March 2023, as a Party to the Convention and pursuant to Article 35(7)(b) of
the Convention, Romania notified the confirmation of the completion of its internal
procedures for the entry into effect of the provisions of the Convention with respect
to the following agreements: Albania, Australia, Austria, Belgium, Bosnia and Herzegovina,
Bulgaria, Canada, China (People’s Republic of), Croatia, Cyprus, Czech Republic, Denmark,
Egypt, Estonia, Finland, France, Georgia, Greece, Hong Kong (China), Hungary, Iceland,
India, Indonesia, Ireland, Israel, Japan, Jordan, Kazakhstan, Korea, Latvia, Lithuania,
Luxembourg, Malaysia, Malta, Netherlands, Norway, Pakistan, Poland, Portugal, Qatar,
Russian Federation, San Marino, Saudi Arabia, Serbia, Singapore, Slovak Republic,
Slovenia, South Africa, Spain, Sweden, Thailand, Ukraine, United Arab Emirates, United
Kingdom and Uruguay.
Pursuant to Article 35(7)(b) of the Convention, the Depositary hereby notifies the
other Contracting Jurisdictions on behalf of Romania.
The notifications made pursuant to Article 35(7)(b) are also accessible on the OECD
website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
03-07-2023
On 3 July 2023, as a Party to the Convention and pursuant to Article 35(7)(b) of the
Convention, Romania notified the confirmation of the completion of its internal procedures
for the entry into effect of the provisions of the Convention with respect to the
following agreement: Mexico.
Pursuant to Article 35(7)(b) of the Convention, the Depositary hereby notifies the
other Contracting Jurisdiction on behalf of Romania.
The notifications made pursuant to Article 35(7)(b) are also accessible on the OECD
website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
05-09-2023
On 5 September 2023, as a Party to the Convention and pursuant to Article 35(7)(b)
of the Convention, Romania notified the confirmation of the completion of its internal
procedures for the entry into effect of the provisions of the Convention with respect
to the following agreement: Vietnam.
Pursuant to Article 35(7)(b) of the Convention, the Depositary hereby notifies the
other Contracting Jurisdiction on behalf of Romania.
The notifications made pursuant to Article 35(7)(b) are also accessible on the OECD
website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
10-11-2023
On 10 November 2023, as a Party to the Convention and pursuant to Article 35(7)(b)
of the Convention, Romania notified the confirmation of the completion of its internal
procedures for the entry into effect of the provisions of the Convention with respect
to the following agreement: Tunisia.
The notification made pursuant to Article 35(7)(b) is accessible on the OECD website:
http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
11-01-2024
On 11 January 2024, as a Party to the Convention and pursuant to Article 35(7)(b) of the Convention, Romania notified the confirmation of the completion of its internal procedures for the entry into effect of the provisions of the Convention with respect to the following agreement: Armenia. The notifications made pursuant to Article 35(7)(b) are accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
Russische Federatie
25-06-2019
Pursuant to Articles 28(5) and Article 29(1) of the Convention, the Russian Federation deposited its list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
30-04-2020
Pursuant to Article 35(7)(b) of the Convention, the Russian Federation notified in
relation to Article 35(7)(a)(i) of the Convention the confirmation of the completion
of its internal procedures for the entry into effect of the provisions of the Convention
with respect to the following agreements:
Australia, Austria, Belgium (old), Canada, Denmark, Finland, France, Iceland, India,
Ireland, Israel, Latvia, Lithuania, Luxembourg, Malta, Netherlands, New Zealand, Norway,
Poland, Qatar, Serbia, Singapore, Slovak Republic, Slovenia, Ukraine, United Arab
Emirates, United Kingdom.
The provisions of the Convention will enter into effect for the listed agreements
in accordance with the provisions of Article 35(1) as modified by Article 35(7)(a).
Pursuant to Article 35(7)(b) of the Convention, the Depositary hereby notifies the
other Contracting Jurisdictions on behalf of the Russian Federation and upon its request.
The notification made pursuant to Article 35(7)(b) is accessible on the OECD website:
http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
26-11-2020
On 26 November 2020, as a Party to the Convention and pursuant to Article 35(7)(b)
of the Convention, the Russian Federation notified the confirmation of the completion
of its internal procedures for the entry into effect of the provisions of the Convention
with respect to the following agreements: Cyprus, Czech Republic, Indonesia, Kazakhstan,
Korea, Portugal and Saudi Arabia.
The notifications made pursuant to Article 35(7)(b) are accessible on the OECD website:
http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
21-10-2021
On 21 October 2021, as a Party to the Convention and pursuant to Article 35(7)(b)
of the Convention, the Russian Federation notified the confirmation of the completion
of its internal procedures for the entry into effect of the provisions of the Convention
with respect to the following agreements: Albania, Chile, Croatia, Egypt, Greece,
Hungary, and Malaysia.
On 21 October 2021, as a Party to the Convention and pursuant to Article 35(7)(b)
of the Convention, the Russian Federation also notified the confirmation of the completion
of its internal procedures for the entry into effect of the additional notifications
made by the following Party with respect to their agreement: Kazakhstan.
The notifications made pursuant to Article 35(7)(b) are accessible on the OECD website:
http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
21-02-2023
On 7 February 2023, as a Party to the Convention and pursuant to Article 35(7)(b)
of the Convention, the Russian Federation notified the confirmation of the completion
of its internal procedures for the entry into effect of the provisions of the Convention
with respect to the following agreements: Bulgaria, People’s Republic of China, South
Africa, Spain and Thailand.
The notifications made pursuant to Article 35(7)(b) are accessible on the OECD website:
http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
09-02-2024
On 17 January 2024, as a Party to the Convention and pursuant to Article 35(7)(b) of the Convention, the Russian Federation notified the confirmation of the completion of its internal procedures for the entry into effect of the provisions of the Convention with respect to the following agreements: Armenia, Hong Kong, Mexico, Romania and Viet Nam. The notifications made pursuant to Article 35(7)(b) are accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
San Marino
11-03-2020
Pursuant to Articles 28(5) and 29(1) of the Convention, San Marino deposited its list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
Saudi-Arabië
23-01-2020
Pursuant to Articles 28(5) and Article 29(1) of the Convention, Saudi Arabia deposited its list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
Senegal
10-05-2022
Pursuant to Articles 28(5) and 29(1) of the Convention, Senegal deposited a list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
Servië
05-06-2018
Pursuant to Articles 28(6) and 29(3) of the Convention, Serbia deposited its list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf
27-09-2023
Serbia notifies the date of entry into force of the agreements with Indonesia and
Morocco included in the list of agreements previously notified under Article 2(1)(a)(ii)
of the Convention,
The Consolidated MLI Position reflecting the updated list of reservations and notifications
is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
Seychellen
14-12-2021
Pursuant to Articles 28(5) and 29(1) of the Convention, the Seychelles deposited a list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
Singapore
21-12-2018
Pursuant to Articles 28(5) and 29(1) of the Convention, Singapore deposited its list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
Slovenië
22-03-2018
Pursuant to Articles 28(5) and Article 29(1) of the Convention, Slovenia deposited its list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
23-03-2023
On 23 March 2023, as a Party to the Convention and pursuant to Article 29(5) of the
Convention, Slovenia notified the Depositary of the date of entry into force of an
agreement included in the list of agreements previously notified under Article 2(1)(a)(ii)
of the Convention.
The Consolidated MLI Position reflecting the updated list of reservations and notifications
is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
Slowakije
26-09-2018
Pursuant to Articles 28(6) and Article 29(3) of the Convention, Slovakia deposited its list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
02-10-2024
Pursuant to Article 35(1)(b) of the Convention, the Slovak Republic notified that
it intends to apply a shorter period than six calendar months with respect to its
agreement with Germany and that it intends to apply a period of two calendar months.
The notifications are accessible on the OECD website: https://www.oecd.org/content/dam/oecd/en/topics/policy-sub-issues/beps-mli/beps-mli-signatories-and-parties.pdf
Spanje
07-06-2017
In the event that the present Convention were to be extended to the British Overseas
Territory of Gibraltar or to be signed by its authorities, Spain wishes to make the
following declaration:
1. Gibraltar is a non‐autonomous territory for the international relations of which
the United Kingdom is responsible and which is subject to a decolonization process
in accordance with the relevant decisions and resolutions of the General Assembly
of the United Nations.
2. The authorities of Gibraltar are of a local nature and exercise exclusively internal
competences which have their origin and their foundation in the distribution and attribution
of competences performed by the United Kingdom, in compliance with its internal legislation,
in its capacity as sovereign State on which the mentioned non‐autonomous territory
depends.
3. As a result, should the Gibraltarian authorities participate in the application
of this Agreement it will be understood as effected exclusively within the scope of
the internal competences of Gibraltar, and it cannot be considered to produce any
change whatsoever in relation with what was established in the two preceding paragraphs.
4. The procedure established by the Regime relating to Gibraltar authorities in the
context of certain international treaties agreed upon by Spain and the United Kingdom
on 19 December 2007 (together with the “Agreed arrangements relating to Gibraltar
authorities in the context of the European Union and European Community instruments
and related Treaties of 19th April 2000”) is applicable to this Convention.
5. The application to Gibraltar of the present Convention cannot be interpreted as
recognition of any rights or situations involving matters not included in Article
10 of the Treaty of Utrecht of 13 July 1713, signed by the crowns of Spain and Great
Britain.
28-09-2021
Pursuant to Articles 28(5) and 29(1) of the Convention, Spain deposited a list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
01-06-2022
On 1 June 2022, as a Party to the Convention and pursuant to Article 35(7)(b) of the
Convention, Spain notified the confirmation of the completion of its internal procedures
for the entry into effect of the provisions of the Convention with respect to the
following agreements: Albania, Germany, Andorra, Saudi Arabia, Australia, Austria,
Barbados, Belgium, Bosnia and Herzegovina, Canada, Qatar, Czech Republic, Chile, Cyprus,
Korea, Costa Rica, Croatia, Egypt, United Arab Emirates, Slovak Republic, Slovenia,
Estonia, Finland, France, Georgia, Greece, Hungary, Indonesia, Ireland, Iceland, Israel,
Kazakhstan, Latvia, Lithuania, Luxembourg, Malaysia, Malta, New Zealand, Oman, Pakistan,
Panama, Poland, Portugal, United Kingdom, Russia, Serbia, Singapore, Uruguay, India
and Romania.
On 1 June 2022, as a Party to the Convention and pursuant to Article 35(7)(b) and
36 of the Convention, Spain notified the confirmation of the completion of its internal
procedures for the entry into effect of the provisions of Part VI of the Convention
(Arbitration) with respect to the following agreements: Germany, Andorra, Australia,
Austria, Barbados, Belgium, Canada, Slovenia, Finland, France, Greece, Hungary, Ireland,
Luxembourg, Malta, New Zealand, Portugal, United Kingdom and Singapore.
The notifications made pursuant to Article 35(7)(b) are accessible on the OECD website:
http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
30-11-2022
On 30 November 2022, as a Party to the Convention and pursuant to Article 35(7)(b) of the Convention, Spain notified the confirmation of the completion of its internal procedures for the entry into effect of the provisions of the Convention with respect to the following agreements: Hong Kong (China), Senegal and Thailand. The notifications made pursuant to Article 35(7)(b) are accessibile on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
01-06-2023
On 1 June 2023, as a Party to the Convention and pursuant to Article 35(7)(b) of the
Convention, Spain notified the confirmation of the completion of its internal procedures
for the entry into effect of the provisions of the Convention with respect to the
following agreements: Bulgaria and South Africa.
The notifications made pursuant to Article 35(7)(b) are accessible on the OECD website:
http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
10-11-2023
On 10 November 2023, as a Party to the Convention and pursuant to Article 35(7)(b)
of the Convention, Spain notified the confirmation of the completion of its internal
procedures for the entry into effect of the provisions of the Convention with respect
to the following agreements: Mexico, Tunisia and Vietnam.
On 10 November 2023, as a Party to the Convention and pursuant to Article 35(7)(b)
of the Convention, Spain notified the confirmation of the completion of its internal
procedures for the entry into effect of the withdrawal of a reservation made by the
following Party with respect to its agreement: Finland.
On 10 November 2023, as a Party to the Convention and pursuant to Article 35(7)(b)
of the Convention, Spain notified the confirmation of the completion of its internal
procedures for the entry into effect of the additional notifications made by the following
Party with respect to its agreement.
The notifications made pursuant to Article 35(7)(b) are accessible on the OECD website:
http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
31-05-2024
On 31 May 2024, as a Party to the Convention and pursuant to Article 35(7)(b) of the
Convention, Spain notified the confirmation of the completion of internal procedures
for the entry into effect of the provisions of the Convention with respect to the
following agreement: Armenia.
The notifications made pursuant to Article 35(7)(b) are accessible on the OECD website:
http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
02-10-2024
Pursuant to Article 35(1)(b) of the Convention, Spain hereby notifies that it intends
to apply a shorter period than six calendar months with respect to the following agreement:
Germany, 2 calendar months.
The notifications are accessible on the OECD website: https://www.oecd.org/content/dam/oecd/en/topics/policy-sub-issues/beps-mli/beps-mli-signatories-and-parties.pdf
Thailand
31-03-2022
Pursuant to Articles 28(5) and 29(1) of the Convention, Thailand deposited a list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
Tsjechië
13-05-2020
Pursuant to Articles 28(5) and 29(1) of the Convention, the Czech Republic deposited its list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
16-08-2024
a) Pursuant to Article 29(5) of the Convention, Czechia extends the list of agreements
notified under Article 2(1)(a)(ii) of the Convention;
b) Pursuant to Article 29(5) of the Convention, Czechia makes additional notifications
under Articles 6(5), 7(17) and 16(6) of the Convention; and
c) Czechia notifies a technical correction to the list of reservations and notifications
deposited by Czechia upon the deposit of its instrument of ratification of the Convention
on 13 May 2020.
The MLI Position regarding the extended list of reservations and notifications and
the notification of the technical correction are accessible on the OECD website: https://www.oecd.org/content/dam/oecd/en/topics/policy-sub-issues/beps-mli/beps-mli-signatories-and-parties.pdf.
Tunesië
24-07-2023
Pursuant to Articles 28(5) and 29(1) of the Convention, Tunisia deposited a list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
Turkije
07-06-2017
The Republic of Turkey declares that it will implement the provisions of Multilateral
Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit
Shifting-MLI only to the States Parties with which it has diplomatic relations.
Turkey's signature of this Convention should in no way be construed as the recognition
of the so-called "Republic of Cyprus" by Turkey, nor should it imply any obligation
on the part of Turkey to enter into any dealing with the so-called Republic of Cyprus
within the framework of the said Convention.
Uruguay
06-02-2020
Pursuant to Articles 28(6) and Article 29(3) of the Convention, Uruguay deposited its list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
Verenigd Koninkrijk
25-10-2017
Pursuant to Articles 28(5) and Article 29(1) of the Convention, the Isle of Man deposited its list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
15-12-2017
Pursuant to Articles 28(5) and Article 29(1) of the Convention, Jersey deposited its list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
29-06-2018
Pursuant to Articles 28(5) and 29(1) of the Convention, the United Kingdom deposited its list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
12-02-2019
Pursuant to Articles 28(5) and Article 29(1) of the Convention, Guernsey deposited its list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
Verenigde Arabische Emiraten
29-05-2019
Pursuant to Articles 28(5) and Article 29(1) of the Convention, United Arab Emirates deposited its list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
Vietnam
23-05-2023
Pursuant to Articles 28(5) and 29(1) of the Convention, Viet Nam deposited a list
of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
Zuid-Afrika
30-09-2022
Pursuant to Articles 28(6) and 29(3) of the Convention, South Africa deposited a list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
Zuid-Korea
13-05-2020
Pursuant to Articles 28(5) and 29(1) of the Convention, Korea deposited its list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
Zweden
22-06-2018
Pursuant to Articles 28(6) and 29(3) of the Convention, Sweden deposited its list
of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
Zwitserland
29-08-2019
Pursuant to Articles 28(6) and Article 29(3) of the Convention, Switzerland deposited its list of reservations and notifications which is accessible on the OECD website: http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
27-05-2020
Pursuant to Article 35(7)(b) of the Convention, Switzerland notified in relation to
Article 35(7)(a)(i) of the Convention the confirmation of the completion of its internal
procedures for the entry into effect of the provisions of the Convention with respect
to the following agreement: Luxembourg.
The provisions of the Convention will enter into effect for the listed agreement in
accordance with the provisions of Article 35(1) as modified by Article 35(7)(a).
Pursuant to Article 35(7)(b) of the Convention, Switzerland notifies the other Contracting
Jurisdiction.
The notification made pursuant to Article 35(7)(b) is accessible on the OECD website:
http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
18-12-2020
On 18 December 2020, as a Party to the Convention and pursuant to Article 35(7)(b)
of the Convention, Switzerland notified the confirmation of the completion of its
internal procedures for the entry into effect of the provisions of the Convention
with respect to the following agreements: Lithuania and the Czech Republic.
The notification made pursuant to Article 35(7)(b) is accessible on the OECD website:
http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.
16-12-2022
On 16 December 2022, as a Party to the Convention and pursuant to Article 35(7)(b)
of the Convention, Switzerland notified the confirmation of the completion of its
internal procedures for the entry into effect of the provisions of the Convention
with respect to the following agreement: Iceland.
The notification made pursuant to Article 35(7)(b) is accessible on the OECD website:
http://www.oecd.org/tax/treaties/beps-mli-signatories-and-parties.pdf.