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.
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
Impact of the MLI on the Luxembourg-Singapore tax treaty
Belgium deposits the MLI ratification instrument
Dutch Parliament approves MLI ratification bill
Margriet Lukkien
Partner Tax adviserMargriet Lukkien is a partner in Loyens & Loeff’s International Tax Services practice group.
T: +31 20 578 54 18 E: margriet.lukkien@loyensloeff.com
Charlotte Kiès
Partner Tax adviserCharlotte Kiès, tax adviser, is a member of the International Tax Services practice group in our Amsterdam office. She is also a member of the Latin America region team, Energy team and the multilateral instrument (MLI) team.
T: +31 20 578 51 67 M: +31 6 51 88 31 32 E: charlotte.kies@loyensloeff.com
Fabian Sutter
Partner Attorney at law, Swiss certified tax expertFabian Sutter, attorney at law and Swiss certified tax expert, is a partner in our Zurich office. He focusses on Swiss and international taxation, in particular corporate reorganizations and restructurings, M&A, financing and capital market transactions, transfer pricing, private equity, real estate transactions as well as tax litigation.
T: +41 43 434 67 14 M: +41 79 398 76 39 E: fabian.sutter@loyensloeff.com
Benno Daemen
Associate Attorney at lawBenno Daemen, attorney at law, is a member of the Loyens & Loeff International Tax Services Practice Group in Belgium. He is an associate in our office in Brussels and specialises in corporate income tax and international tax law.
T: +32 2 773 23 67 E: benno.daemen@loyensloeff.com
Pierre-Antoine Klethi
Senior Associate Attorney at law / Avocat / Tax AdviserPierre-Antoine Klethi, senior associate, is a member of the Tax and Investment Management Practice Groups in our Luxembourg office. He focuses on corporate taxation (including relevant international developments), fund structuring and EU State Aid investigations.
T: +352 466 230 429 E: pierre-antoine.klethi@loyensloeff.com