OECD Multilateral Instrument (MLI)

In Tax

Assessing and addressing MLI-led changes to tax treaties represent one of the most significant cross-border challenges our clients have faced in many years.

What EY can do for you

The BEPS Multilateral Instrument or “MLI” enables jurisdictions to swiftly implement the treaty-based recommendations from the BEPS package, including some of the minimum standards. The MLI has been signed by over 75 jurisdictions and it represents one of the most important changes to cross-border tax norms in history. It will impact business structures, transactions and potentially even business models themselves.

Following the deposit of the fifth instrument of ratification, acceptance or approval of the MLI on late March 2018, the MLI will enter into force for the first five jurisdictions on 1 July 2018. The MLI will have effect for the rest of signatories, once they deposit their instrument with the OECD and certain time has elapsed. Businesses need to stay abreast of the state of the entry into force and effect of the MLI in the jurisdictions where they operate and understand and monitor the changes forthcoming to over 2,000 tax treaties.

Our global reach combined with our deep technical experience and business-focused tax advisory capabilities leave us very well positioned to assist our clients in addressing this multi-jurisdictional issue that goes to the very heart of their business structure and operations.

We can help you navigate the MLI and understand what it means to your business and structure. This ranges from the interpretation of the MLI itself to whether a specific provision is applicable and its implications (e.g., from when it has an effect and how it impacts your operations).    


Are you staying up-to-date on the OECD project on Base Erosion and Profit Shifting (BEPS) and the BEPS-driven developments already happening in individual countries?

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