Guidance

Multilateral convention to implement tax treaty related measures to prevent base erosion and profit shifting

Find the final list of UK reservations and notifications made on deposit of the instrument of ratification.

Documents

Details

The UK signed the Multilateral Instrument (MLI) in Paris on 7 June 2017 and deposited its instrument of ratification and final list of reservations and notifications on 29 June 2018.

The MLI will enter into force for the UK on 1 October 2018 and will begin to have effect in the UK for UK tax treaties from:

  • 1 January 2019 for taxes withheld at source
  • 1 April 2019 for Corporation Tax
  • 6 April 2019 for Income Tax and Capital Gains Tax

The date which individual UK tax treaties are modified by the MLI depends on the date our treaty partners deposit their own instruments of ratification, acceptance or approval.

Details of the date individual treaties are modified by the MLI, and of the modifications themselves, will be published on the relevant country tax treaties page.

The text of the MLI and explanatory statement to the MLI are available on the Organisation for Economic Co-operation and Development (OECD) website.

Published 16 April 2018
Last updated 16 July 2018 + show all updates
  1. The final list of UK reservations and notifications made on deposit of the instrument of ratification documents have been added.
  2. First published.