The Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (“MLI”) is an outcome of the BEPS Action 15 Report and operates to modify tax treaties between two or more Parties in order to implement BEPS measures in a swift manner.
The MLI has entered into force on 1st July 2018 and it started producing effect from 1st January 2019. As on date, 95 jurisdictions are signatories to the MLI. The OECD has reported that Croatia and Malaysia are the latest jurisdictions to have deposited their instrument of ratification. With this, 63 jurisdictions have ratified the MLI.
India signed the MLI on 07 June 2017 and deposited its instrument of ratification on 25 June 2019, as a result of which, MLI entered into force for India on 01 October 2019. Out of 93 DTAAs (called as CTAs under the MLI) notified by India, 60 countries have signed the MLI as of now, and out of these 60 countries, 44 jurisdictions have ratified the MLI. Thus, MLI provisions will modify these 44 CTAs in accordance with notifications made by India and the respective treaty partner. A complete list of these 44 CTAs is enclosed.