Lesotho, Thailand and Viet Nam sign landmark agreement to strengthen their tax treaties


09/02/2022 – Today, Lesotho, Thailand and Viet Nam signed the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (the Convention or MLI), becoming the 97th, 98th and 99th jurisdiction to join the Convention, which now covers over 1800 bilateral tax treaties.


Lesotho signs landmark agreement to strengthen its tax treaties

L-R: H.E. Mrs. Barbara Masupha SENATE (Ambassador of the Kingdom of Lesotho to Germany) and Mr. Yoshiki TAKEUCHI (Deputy Secretary-General, OECD)


On 1 February 2022, over 880 treaties concluded among the 68 jurisdictions which have ratified, accepted or approved the Convention had already been modified by the Convention. An additional 940 treaties will be modified once the Convention will have been ratified by all Signatories.


The Convention, negotiated by more than 100 countries and jurisdictions under a mandate from the G20 Finance Ministers and Central Bank Governors, is one of the most prominent results of the OECD/G20 BEPS Project. It is the world’s leading instrument for updating bilateral tax treaties and reducing opportunities for tax avoidance by multinational enterprises. Measures included in the Convention address treaty abuse, strategies to avoid the creation of a “permanent establishment”, and hybrid mismatch arrangements. The Convention also enhances the dispute resolution mechanism, especially through the addition of an optional provision on mandatory binding arbitration, which has been taken up by 33 jurisdictions.


All published opinions of the Conference of the Parties to the MLI are available at


The text of the Convention, the explanatory statement, background information, database, and positions of each signatory are available at


Journalists wishing to obtain further information are invited to contact Pascal Saint-Amans, Director of the Centre for Tax Policy and Administration (CTP) or the CTP Communications team.


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