Tax treaties

Conference of the Parties to the MLI approve an opinion on interpretation and implementation


20/05/2021 - On 3 May 2021, the Conference of the Parties to the MLI approved an opinion that sets out a series of guiding principles for addressing questions about the interpretation and implementation of the MLI. Those principles, discussed and approved by the Conference of the Parties to the MLI, were drawn from public international law, the design of the MLI itself, and its drafting history.



The MLI so far covers 95 jurisdictions and has been ratified by 65 jurisdictions. It is the first multilateral treaty of its kind, allowing jurisdictions to swiftly transpose results from the OECD/G20 BEPS Project into their existing tax treaties, transforming the way tax treaties are modified. The MLI became effective on 1 January 2021 for approximately 650 treaties concluded among the 65 jurisdictions, with an additional 1200 treaties to become effectively modified once the MLI will have been ratified by all Signatories. The MLI implements the tax-treaty related BEPS measures on hybrid mismatch arrangements, treaty abuse and permanent establishment. It also strengthens provisions to resolve treaty disputes, including through mandatory binding arbitration, which has been taken up by 31 Parties.


The text of the MLI, its Explanatory Statement and background information are available at:


Media queries should be directed to Pascal Saint-Amans, Director of the OECD Centre for Tax Policy and Administration, (+33 6 26 30 49 23) or to [email protected].


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