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Canada and Switzerland Deposit Ratification Instruments for BEPS MLI — Orbitax Tax News & Alerts

On 29 August 2019, Canada and Switzerland deposited their ratification instruments for the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). Based on the date of deposit, the MLI will enter into force for both Canada and Switzerland on 1 December 2019 although its entry into force for both Canada and Switzerland’s covered agreements (tax treaties) will depend on the ratification of the MLI by the counterparty to a particular covered agreement.

The MLI will generally enter into force for a particular covered agreement on the first day of the month following a three-month period after both parties to the covered agreement have deposited their ratification instruments. Once in force, the provisions of the MLI will generally apply for a covered agreement from 1 January of the year following its entry into force in respect of withholding taxes, and for all other taxes with respect to taxable periods beginning on or after the expiration of a 6-month period following the date of entry into force.