Four countries deposit new BEPS MLI notifications

Belgium, Estonia, the Netherlands, and Qatar have deposited new notifications under the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (BEPS MLI) subsequent to their ratification.

Estonia has notified, in relation to Article 35(7)(a)(i) of the BEPS MLI, the completion of its internal procedures for the entry into effect of the provisions of the BEPS MLI with respect to its treaties with Austria, Cyprus, Finland, Latvia, Poland, Slovak Republic and Ukraine in accordance with Article 35(7)(b) of the BEPS MLI; and the Netherlands and Qatar have notified additional bilateral treaties to which the BEPS MLI can apply and made additional notifications with respect to provisions of the BEPS MLI. Belgium made an additional notification with respect to its treaty with the Netherlands.

The BEPS MLI entered into force for Belgium on October 1, 2019, for Estonia on May 1, 2021, for the Netherlands on July 1, 2019, and for Qatar on April 1, 2020. The new notifications made by those jurisdictions will take effect in accordance with Articles 29 and 35 of the BEPS MLI.

The BEPS MLI, which covers over 1700 bilateral tax treaties, underlines the strong commitment of the 96 jurisdictions that have already joined it to prevent the abuse of tax treaties and address BEPS by multinational enterprises. The BEPS MLI has already started to impact the bilateral treaties of 67 jurisdictions that have ratified it. From January 1, 2022, it is expected to impact over 850 treaties concluded among those 67 jurisdictions, with an additional 900 treaties to become modified once the BEPS MLI is ratified by all Signatories.

See Announcement