The final action of the BEPS Action Plan, Action 15, related to the development of a multilateral instrument (“MLI”) that countries could use to implement various treaty-related measures introduced by the wider BEPS agenda. The MLI allows for swift implementation of these measures, circumventing the need to update each individual treaty.
In order for the MLI to apply to, and modify, any specific existing treaty, both parties must have signed the MLI, completed all necessary procedures for entering the MLI into force in their respective countries and deposited with the OECD their ratification instruments and ‘positions’ where there are choices available.
At the time of writing, the MLI has been signed by 84 jurisdictions, and entered into force for 9 of those, including the UK. Click here to see a timeline of the MLI’s implementation across the jurisdictions which have signed.
