Belgium, Estonia, the Netherlands and Qatar deposit new notifications under the Multilateral BEPS Convention


25/11/2021 – Belgium, Estonia, the Netherlands and Qatar have deposited new notifications under the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (Multilateral Convention or MLI) subsequent to their ratification:

  • Estonia has notified, in relation to Article 35(7)(a)(i) of the MLI, the completion of its internal procedures for the entry into effect of the provisions of the MLI with respect to its treaties with Austria, Cyprus, Finland, Latvia, Poland, Slovak Republic and Ukraine in accordance with Article 35(7)(b) of the MLI; and
  • The Netherlands and Qatar have notified additional bilateral treaties to which the MLI can apply and made additional notifications with respect to provisions of the MLI. Belgium made an additional notification with respect to its treaty with the Netherlands.


The MLI entered into force for Belgium on 1 October 2019, for Estonia on 1 May 2021, for the Netherlands on 1 July 2019 and for Qatar on 1 April 2020. The new notifications made by those jurisdictions will take effect in accordance with Articles 29 and 35 of the MLI.


The MLI, which covers over 1700 bilateral tax treaties, underlines the strong commitment of the 96 jurisdictions that have already joined it to prevent the abuse of tax treaties and address base erosion and profit shifting (BEPS) by multinational enterprises. The MLI has already started to impact the bilateral treaties of 67 jurisdictions that have ratified it. From 1 January 2022, it is expected to impact over 850 treaties concluded among those 67 jurisdictions, with an additional 900 treaties to become modified once the MLI is ratified by all Signatories.


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


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