Tax treaties

Germany and Pakistan deposit their instrument of ratification for the Multilateral BEPS Convention and other updates


18/12/2020 - Germany and Pakistan have deposited their instrument of ratification for the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (Multilateral Convention or MLI), which now covers almost 1700 bilateral tax treaties, thus underlining its strong commitment to prevent the abuse of tax treaties and base erosion and profit shifting (BEPS) by multinational enterprises. For Germany and Pakistan, the MLI will enter into force on 1 April 2021.


With 95 jurisdictions currently covered by the MLI, today’s ratification by Germany and Pakistan now brings to 59 the number of jurisdictions which have ratified, accepted or approved it. The Multilateral Convention will become effective on 1 January 2021 for over 600 treaties concluded among the 59 jurisdictions, with an additional 1200 treaties to become effectively modified once the MLI will have been ratified by all Signatories.


In addition, Switzerland notified in relation to Article 35(7)(a)(i) of the MLI the confirmation of the completion of its internal procedures for the entry into effect of the provisions of the MLI with respect to its treaties with the Czech Republic and Lithuania in accordance with Article 35(7)(b) of the MLI.


The text of the Multilateral Convention, the explanatory statement, background information, database, and positions of each signatory are available at


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