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Multilateral Instrument (MLI)

The multilateral instrument (MLI) implements the treaty related anti-tax avoidance measures of the BEPS project in bilateral tax treaties.

A highly innovative aspect of the BEPS project, the MLI allows for the relatively rapid inclusion in existing bilateral tax treaties of measures against treaty shopping, artificial avoidance of the PE status and hybrid mismatches, as well as improvements of the dispute resolution mechanism. The MLI currently covers 94 jurisdictions, including the Netherlands, Belgium, Luxembourg and Switzerland. As from 1 January 2020 the MLI affects multiple Covered Tax Agreements and its scope of application is expanding rapidly. It will have a substantial impact on more than 1,500 existing bilateral tax treaties.

Our team of experts closely monitors all developments related to the MLI.

MLI Quick Scan: find out how MLI will impact your business

Our MLI Quick Scan will provide you with a complete report on the impact the MLI will have on your business. It serves as the ideal basis to select those issues that really matter and allows you to really focus on your business needs. Please contact us for more information.

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MLI overview with regard to the Netherlands, Belgium, Luxembourg and Switzerland

As from 1 January 2020, the MLI starts to modify a large number of existing bilateral tax treaties with anti-tax avoidance measures developed in the OECD BEPS project. The impact of these bilateral choices on a specific tax treaty will also depend on the choices made by the other treaty jurisdiction of that specific tax treaty.

Overview: MLI choices made by the Netherlands, Belgium, Luxembourg and Switzerland