Action 15 Multilateral Instrument

The Multilateral Instrument (BEPS MLI) offers concrete solutions for governments to close loopholes in international tax treaties by transposing results from the BEPS Project into bilateral tax treaties worldwide. The BEPS MLI allows governments to implement agreed minimum standards to counter treaty abuse and to improve dispute resolution mechanisms while providing flexibility to accommodate specific tax treaty policies.

Action overview


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How does it work?

The Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting ("Multilateral Instrument" or "BEPS MLI") allows governments to modify existing bilateral tax treaties in a synchronised and efficient manner to implement the tax treaty measures developed during the BEPS Project, without the need to expend resources renegotiating each treaty bilaterally.

Information brochure

How many jurisdictions have joined the Multilateral Instrument?

In November 2016, over 100 jurisdictions concluded negotiations on the BEPS MLI that will swiftly implement a series of tax treaty measures to update international tax rules and lessen the opportunity for tax avoidance by multinational enterprises. The BEPS MLI already covers over 100 jurisdictions and entered into force on 1 July 2018. Signatories include jurisdictions from all continents and all levels of development and other jurisdictions are also actively working towards signature.

Signatories and Parties

When will the Multilateral Instrument take effect?

The BEPS MLI entered into force on 1 July 2018 and its provisions entered into effect for the first provisions on 1 January 2019. More information on entry into force and effect for each Party and their Covered Tax Agreements can be found in the list of Signatories and Parties (BEPS MLI Positions) and the BEPS MLI Toolkit & Database.

Toolkit & database

In which languages is the Multilateral Instrument available?

Only the signed English and French versions are the authentic BEPS MLI texts applicable. Members of the "ad hoc Group" that negotiated the BEPS MLI have translated it into Arabic, BulgarianChinese, Dutch, German, GreekItalian, Japanese, Portuguese, Serbian, Spanish and Swedish. These translations of the BEPS MLI in other languages are provided only for information purposes.

Beyond saving signatories from the burden of re-negotiating thousands of tax treaties bilaterally, the convention results in more certainty and predictability for businesses, and a better functioning international tax system for the benefit of our citizens. Angel Gurría, OECD Secretary-General, 2006-2021

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Discover the international state of play with this interactive map presenting key indicators and outcomes of the OECD's work on international tax matters.

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Action specific content

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Text of the Multilateral Instrument

The text of the Multilateral Instrument was developed through a negotiation involving more than 100 countries and jurisdictions and adopted on 24 November 2016, under a mandate delivered by G20 Finance Ministers and Central Bank Governors at their February 2015 meeting.

Explanatory Statement

The Explanatory Statement to accompany the BEPS MLI provides clarification to the approach taken in the BEPS MLI and how each provision is intended to affect Covered Tax Agreements. It reflects the agreed understanding of the negotiators with respect to the Convention. It includes descriptions of the types of treaty provisions which are intended to be covered and the ways in which they are intended to be modified. The Explanatory Statement was adopted in English and French on 24 November 2016.


Tools, guidance and the matching database

The OECD has developed a toolkit for the application of the BEPS MLI, including innovative tools to facilitate the interpretation and application of this innovative legal instrument. The toolkit will be expanded over time but includes guidance documents, interactive flowcharts, and the BEPS MLI matching database.

BEPS MLI Toolkit

Opinions of the BEPS MLI Conference of the Parties

In accordance with Article 31(1) of the BEPS MLI, the Conference of the Parties to the BEPS MLI is responsible for taking any decisions or exercising any functions as may be required or appropriate under the provisions of the BEPS MLI.

View all published opinions