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OECD: Report clarifying effect of MLI on tax treaties

OECD report on multilateral instrument (MLI)

The Organisation for Economic Cooperation and Development (OECD) today released a report that provides an overview of changes to tax treaties resulting from application of the multilateral instrument (MLI).


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As noted in the OECD release, the MLI currently covers 84 jurisdictions, and beginning 1 January 2019, the MLI will apply for the first 47 tax treaties concluded among the 15 jurisdictions that have deposited their acceptances or ratification instruments.

Today’s OECD report—Guidance for the Development of Synthesised Texts [PDF 1.27 MB] (102 pages)—is intended to present an overview of the modifications to tax treaties resulting from application of the MLI on existing tax treaties.

Separately, the OECD has provided a “Secretariat note” [PDF 51 KB] to clarify the entry into effect rules for tax treaties of jurisdictions that have deposited their ratification instruments as of September 2018.

The OECD noted that several jurisdictions have already started preparing “synthesised texts” by taking into account their own publication requirements and practices. For instance, Poland was the first jurisdiction to publish synthesised texts. The release of today’s guidance is intended to help in the preparation of synthesised texts in a consistent manner.

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