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The Brazilian government has signed the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting, also known as the Multilateral Instrument (MLI).
The MLI was developed by the OECD in 2016, following the recommendations outlined in the Action 15-Final Report of the BEPS Project (Base Erosion and Profit Shifting), an initiative by the OECD and the G20. This voluntary instrument is designed to modernize double taxation agreements (DTAs) worldwide. With this initiative, Brazil joins 105 other countries that have already signed the MLI. The United States and Hungary are planning to reinstate the tax treaty between the two countries.
A meeting in this regard took place on October 17. The tax treaty between the two countries was terminated in 2022. The OECD has published a report that takes stock of the progress made in implementing the BEPS measures and the economic impact these changes have had.
The report shows how the BEPS project has changed the conversation on international tax and established new expectations for corporate responsibility and transparency, strengthening collaboration between tax authorities and enhancing tax certainty through the definition and co-ordinated application of common international tax rules. The report was prepared by the Inclusive Framework ahead of the October 2025 meeting of G20 Finance Ministers and Central Bank Governors under the South African G20 Presidency. The EU Council confirmed the EU list of non-cooperative jurisdictions for tax purposes without changes.
The new list consists of the same 11 jurisdictions as before. These jurisdictions are: American Samoa, Anguilla, Fiji, Guam, Palau, Panama, Russia, Samoa, Trinidad & Tobago, US Virgin Islands, and Vanuatu. The Barbados Revenue Authority is going to be making changes to the Economic Substance Act, according to Minister of Energy and Business, Senator Lisa Cummins.
Cummins made the statement at the media launch of Global Business Week 2025, at the CIBC Caribbean Warrens Great House, Warrens, St. Michael. Cummins told her audience: “There is underway now a process of regulatory reform. You’ve seen much of this happening since last year January, when we had the corporation tax reform. And I’m happy to share with you, if it has not already hit your desk, that the Economic Substance Bill is going to be coming up for consultation on some changes that are going to come down the pipe.” “Together with the International Business Unit and the Barbados Revenue Authority, we are going to be making some changes to the Economic Substance Act, and that will change a number of the ways in which we move from being a nominal tax jurisdiction to being a preferential tax jurisdiction, and that will have significant implications, in a positive way, for the global business sector.” The OECD has released the latest annual peer review results on the implementation of BEPS Action 13 on Country-by-Country Reporting covering 142 Inclusive Framework on BEPS members.
The eighth peer review of BEPS Action 13 assesses how jurisdictions are implementing the Country-by-Country (CbC) Reporting minimum standard as of April 2025 and highlights continued progress in strengthening tax transparency. The BEPS Action 13 peer review is an annual process, and the next peer review report will be released in the third quarter of 2026. The report may be viewed on the OECD’s website. |
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November 2025
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