The multilateral instrument (MLI) implements the treaty related anti-tax avoidance measures of the BEPS project in bilateral tax treaties. Our team of experts closely monitors all developments related to the MLI and is happy to assist.
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 99 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 1,800 existing bilateral tax treaties. The impact of the MLI on these tax treaties will depend on the bilateral choices made by both treaty partners to a specific tax treaty. For more information on the choices made by the Netherlands, Belgium, Luxembourg and Switzerland, please click here