Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting

Party

Montenegro modified

• added reservation
  06-05-2026
  Pursuant to Articles 28(6) and 29(3) of the Convention, Montenegro deposited a list of reservations and notifications which is also accessible on the OECD website: https://www.oecd.org/content/dam/oecd/en/topics/policy-sub-issues/beps-mli/beps-mli-signatories-and-parties.pdf.

• removed reservation
  12-11-2025
  At the time of signature, pursuant to Articles 28(6) and 29(3) of the Convention, Montenegro provided a list of expected reservations and notifications which is accessible on the OECD website: https://www.oecd.org/content/dam/oecd/en/topics/policy-sub-issues/beps-mli/beps-mli-signatories-and-parties.pdf.

Spain modified

• added reservation
  26-05-2026
  On 26 May 2026, as a Party to the Convention and pursuant to Article 35(7)(b) of the Convention, Spain notified the confirmation of the completion of its internal procedures for the entry into effect of the provisions of the Convention with respect to the following agreement: Argentina. Pursuant to Article 35(7)(b) of the Convention, the Depositary hereby notifies the other Contracting Jurisdiction on behalf of Spain. The notifications made pursuant to Article 35(7)(b) are accessible on the OECD website: https://www.oecd.org/content/dam/oecd/en/topics/policy-sub-issues/beps-mli/beps-mli-signatories-and-parties.pdf .

Party

Montenegro modified

• Ratification: 06-05-2026 (R)
• Entry into force: 01-09-2026

Party

Indonesia modified

• added reservation
  12-01-2026
  A. Notification by Indonesia under Article 35(7)(a)(i) On 12 January 2026, as a Party to the Convention and pursuant to Article 35(7)(b) of the Convention, Indonesia notified the confirmation of the completion of its internal procedures for the entry into effect of the provisions of the Convention with respect to the following agreement: Mongolia. B. Notification by Indonesia under Article 35(7)(a)(ii) On 12 January 2026, as a Party to the Convention and pursuant to Article 35(7)(b) of the Convention, Indonesia notified the confirmation of the completion of its internal procedures for the entry into effect of the provisions of the Convention with respect to the following agreements resulting from an extension pursuant to Article 29(5) of the Convention of the list of agreements notified under Article 2(1)(a)(ii): Czech Republic. Pursuant to Article 35(7)(b) of the Convention, the Depositary hereby notifies the other Contracting Jurisdictions on behalf of Indonesia. The notifications made pursuant to Article 35(7)(b) are accessible on the OECD website: https://www.oecd.org/content/dam/oecd/en/topics/policy-sub-issues/beps-mli/beps-mli-signatories-and-parties.pdf.

Party

Finland modified

• added reservation
  11-12-2025
  [...] Finland notified the Depositary of the following technical corrections to its consolidated list of reservations and notifications regarding its agreement with Brazil: The notification under Article 16(6)(a), formerly reading as 10 FEDERATIVE REPUBLIC OF BRAZIL Article 26(1), first sentence should read as follows: 10 THE FEDERATIVE REPUBLIC OF BRAZIL Article 24(1), first sentence The notification under Article 16(6)(b)(ii), formerly reading as 10 FEDERATIVE REPUBLIC OF BRAZIL Article 26(1), second sentence should read as follows: 10 THE FEDERATIVE REPUBLIC OF BRAZIL Article 24(1), second sentence The corrected consolidated list of reservations and notifications made by Finland pursuant to Articles 28(5) and 29(1) of the Convention is now available at https://www.oecd.org/content/dam/oecd/en/topics/policy-sub-issues/beps-mli/beps-mli-signatories-and-parties.pdf.

Party

Georgia modified

• added reservation
  Date unknown
  a) Pursuant to Article 29(5) of the Convention, Georgia extends the list of agreements notified under Article 2(1)(a)(ii) of the Convention, b) Pursuant to Article 29(5) of the Convention, Georgia specifies the additional agreements falling within the scope of its reservation under Article 17(3) of the Convention, c) Pursuant to Article 29(5) of the Convention, Georgia makes additional notifications under Article 6(5) Article 6(6), Article 7(17) and Article 16(6) of the Convention. The Consolidated MLI Position reflecting the updated list of reservations and notifications is accessible on the OECD website: https://www.oecd.org/content/dam/oecd/fr/topics/policy-sub-issues/im-beps/beps-instrument-multilateral-signataires-et-parties.pdf.

Party

Brazil modified

• Reservations / Declarations: Yes

• added reservation
  Date unknown
  At the time of signature, pursuant to Articles 28(7) and 29(4) of the Convention, Brazil provided a provisional list of expected reservations and notifications which is accessible on the OECD website: https://www.oecd.org/content/dam/oecd/en/topics/policy-sub-issues/beps-mli/beps-mli-signatories-and-parties.pdf.

Montenegro modified

• Signature: 12-11-2025
• Reservations / Declarations: Yes
• Objections: No

• added reservation
  Date unknown
  At the time of signature, pursuant to Articles 28(6) and 29(3) of the Convention, Montenegro provided a list of expected reservations and notifications which is accessible on the OECD website: https://www.oecd.org/content/dam/oecd/en/topics/policy-sub-issues/beps-mli/beps-mli-signatories-and-parties.pdf.

Ukraine modified

• added reservation
  Date unknown
  a) Pursuant to Article 29(5) of the Convention, Ukraine extends the list of agreements notified under Article 2(1)(a)(ii) of the Convention, b) Ukraine notifies the date of entry into force of amending instruments included in the list of agreements previously notified under Article 2(1)(a)(ii) of the Convention, c) Pursuant to Article 29(5) and 29(6) of the Convention, Ukraine makes additional notifications under Articles 6(5), 7(17), 9(7), 12(5)(6), 13(7), 14(4) and 16(6) of the Convention. The Consolidated MLI Position reflecting the updated list of reservations and notifications is accessible on the OECD website: https://www.oecd.org/content/dam/oecd/en/topics/policy-sub-issues/beps-mli/beps-mli-signatories-and-parties.pdf.

Party

Brazil added

• Signature: 20-10-2025
• Reservations / Declarations: No
• Objections: No

Party

Argentina modified

• Reservations / Declarations: Yes

• added reservation
  Date unknown
  Pursuant to Articles 28(5) and 29(1) of the Convention, Argentina deposited a list of reservations and notifications which is also accessible on the OECD website: https://www.oecd.org/content/dam/oecd/en/topics/policy-sub-issues/beps-mli/beps-mli-signatories-and-parties.pdf

Party

Argentina modified

• Ratification: 29-09-2025 (R)
• Entry into force: 01-01-2026

Party

Antigua and Barbuda modified

• Signature: 18-06-2025
• Reservations / Declarations: Yes
• Objections: No

• added reservation
  Date unknown
  At the time of signature, pursuant to Articles 28(7) and 29(4) of the Convention, Antigua and Barbuda provided a list of expected reservations and notifications which is accessible on the OECD website: https://www.oecd.org/content/dam/oecd/en/topics/policy-sub-issues/beps-mli/beps-mli-signatories-and-parties.pdf.

Peru modified

• Ratification: 09-06-2025 (R)
• Entry into force: 01-10-2025
• Reservations / Declarations: Yes

• added reservation
  Date unknown
  Pursuant to Articles 28(5) and 29(1) of the Convention, Peru deposited a list of reservations and notifications which is also accessible on the OECD website: https://www.oecd.org/content/dam/oecd/en/topics/policy-sub-issues/beps-mli/beps-mli-signatories-and-parties.pdf