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BEPS MLI in Force for Greece and Hungary — Orbitax Tax News & Alerts

The Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) entered into force for Greece and Hungary on 1 July 2021. With respect to the covered agreements (tax treaties) between these countries and the other countries for which the MLI has already entered into force, the MLI is generally effective from 1 January 2022 in respect of withholding taxes and for taxable periods beginning on or after 1 January 2022 in respect of other taxes (six months after entry into force).

Solely for the purposes of each country's own application of the MLI for other taxes, Greece and Hungary have opted for the MLI to apply from 1 January of the calendar year beginning on or after the expiration of the 6-month period after entry into force. This will not affect the effective date of application for other taxes for initial covered agreements, given the timing of the MLI's entry into force for Greece and Hungary, but may affect the effective date for subsequent covered agreements for which the MLI enters into force.

Click the following links for the definitive lists of reservations and notifications submitted at the time the ratification instruments were deposited for Greece and Hungary.