Base erosion and profit shifting

Albania, Bosnia and Herzegovina and Costa Rica deposit their instruments of ratification and France extends the application for the Multilateral BEPS Convention


22/09/2020 – Albania, Bosnia and Herzegovina and Costa Rica have become the latest countries to deposit their instruments of ratification for the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (the Multilateral Convention or MLI), which now covers almost 1700 bilateral tax treaties. In addition, France has notified additional bilateral treaties to which the MLI can apply.


With 94 jurisdictions currently covered by the Multilateral Convention, these latest ratifications bring to 52 the number of jurisdictions that have already deposited their acceptance or ratification instrument. The Convention will become effective on 1 January 2021 for over 500 treaties concluded among the 52 jurisdictions, with an additional 1200 treaties to become effectively modified once the MLI will have been ratified by all Signatories. More countries are expected to deposit their instruments of ratification before 30 September in order for the MLI to start to take effect as of 1 January 2021.


The Convention is the first multilateral treaty of its kind, allowing jurisdictions to integrate results from the OECD/G20 BEPS Project into their existing networks of bilateral tax treaties. The OECD/G20 BEPS Project delivers solutions for governments to close the gaps in existing international rules that allow corporate profits to "disappear" or be artificially shifted to low or no tax environments, where companies have little or no economic activity.


The Convention, negotiated by more than 100 countries and jurisdictions under a mandate from the G20 Finance Ministers and Central Bank Governors, is one of the most prominent results of the OECD/G20 BEPS Project. It is the world’s leading instrument for updating bilateral tax treaties and reducing opportunities for tax avoidance by multinational enterprises. Measures included in the Convention address treaty abuse, strategies to avoid the creation of a "permanent establishment", and hybrid mismatch arrangements.


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


Journalists wishing to obtain further information are invited to contact Pascal Saint-Amans, Director of the Centre for Tax Policy and Administration (CTP) or the CTP Communications team.


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