The OECD Secretariat today published guidance addressing an effective date issue that has arisen for tax treaties modified by the later signing of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI).
The OECD said that the question involves Article 35 of the MLI. At issue is when the MLI will have effect for taxes withheld at source where the latest of the dates of entry into force of the MLI for a pair of contracting jurisdictions is on January 1 of a given calendar year.
If the dates of entry into force for the pair of contracting jurisdictions is on January 1, 2019, the MLI will have effect for events giving rise to withholding taxes which occur on or after January 1, 2019, the guidance concludes.
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