Structure of the Multilateral Instrument (the MLI) [read]


Structure and Contents of the MLI [read]

The Multilateral Instrument (the MLI) consists of the following parts:

  • Preamble
  • Part I - Scope and interpretation of terms (Articles 1 and 2);
  • Part II - Hybrid mismatches (Articles 3 to 5);
  • Part III - Treaty abuse (Articles 6 to 11);
  • Part IV - Avoidance of permanent establishment status (Articles 12 to 15);
  • Part V - Improving dispute resolution (Articles 16 and 17);
  • Part VI - Arbitration (Articles 18 to 26);
  • Part VII - Final provisions (Articles 27 to 39)

Explanatory Statement

Explanatory Statement to the Multilateral Convention to Implement Tax Treaty-Related Measures to Prevent BEPS [the Multilateral Instrument, the MLI] [read]


Conference of the Parties

Published Opinion of the Conference of the Parties of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (the MLI), issued in accordance with Article 32(2)

Legal notes on the functioning of the MLI under Public international law [read]





Vienna Convention on the Law of Treaties, 23 May 1969 [read]