Synthesized Texts of the MLI provision and the relevant CTAs


OECD releases guidance on Synthesised texts for providing clarity on the impact of the Multilateral Instrument. 

The Guidance has been developed by the OECD Secretariat with input from the members of the Ad hoc Group on the MLI. It can be used by governments that intend to provide insight into the impact of the Convention on existing treaties. Synthesised Texts also provide comprehensive information to taxpayers, auditors, advisors and other users on when the modifications will have effect in each jurisdiction.


See more information about OECD guidance on synthesised texts. [here]





Application of the MLI to Japan's Tax Treaties

 The MLI applies to an existing tax treaty where both parties to that tax treaty have chosen to apply the MLI to it and where the MLI has entered into force for those parties.
  The provisions of the MLI applicable to an existing tax treaty and the timing of entry into effect of the MLI for it are determined depending on the choices of each of the parties to that tax treaty.
  For details of the application of the MLI to the tax treaties between Japan and the jurisdictions which have already deposited their instruments of ratification, acceptance or approval of the MLI, see the table below.

  (*1) The MLI will enter into force on the first day of the month following the expiration of a period of three calendar
          months beginning on the date of the deposit by the Signatory of its instrument of ratification, acceptance or
  (*2) The MLI entered into force on January 1, 2019 for Japan as it deposited its instrument of acceptance on 
          September 26, 2018.
  (*3) The applications of the MLI indicated in the table below are based on the reservations and notifications
          of Japan as of July 22, 2020 and of the other Contracting Jurisdictions submitted on the date set forth
  (*4) “Summary” in the table below contains descriptions of the tax treaty covered by the MLI, the provisions of the
          MLI applicable to that tax treaty and the entry into effect of the MLI for that tax treaty.
     (*5) “Synthesised Text” in the table below is a document containing the consolidated text of the provisions of a tax
          treaty (as it may be amended by amending protocols) and the provisions of the MLI applicable to that tax treaty.
          This document shall be used solely for the purpose of facilitating the understanding of the application of the MLI 
          to a tax treaty and has no legal value.
The Other
Date of Submission
of Reservations
and Notifications
Application of the MLI
Australia 26-09-2018      Summary Synthesised Text
Canada 29-08-2019      Summary Synthesised Text
Czech Republic 13-05-2020      Summary Synthesised Text
Finland 25-02-2019      Summary Synthesised Text
(Japanese(PDF:314KB)English(PDF:135KB)) (*)
France 26-09-2018      Summary Synthesised Text
(Japanese(PDF:272KB)) (*)
India 25-06-2019      Summary Synthesised Text
Indonesia 28-04-2020      Summary Synthesised Text
Ireland 29-01-2019      Summary Synthesised Text
Israel 13-09-2018      Summary   Synthesised Text
Kazakhstan 24-06-2020      Summary Synthesised Text
Korea 13-05-2020      Summary Synthesised Text
Luxembourg 09-04-2019      Summary   Synthesised Text
Netherlands 29-03-2019      Summary   Synthesised Text
New Zealand 27-06-2018      Summary Synthesised Text
Norway 17-07-2019      Summary Synthesised Text
Oman 07-07-2020      Summary Synthesised Text
Poland 23-01-2018      Summary  Synthesised Text
Portugal 28-02-2020      Summary Synthesised Text
Qatar 23-12-2019      Summary Synthesised Text
Saudi Arabia 23-01-2020      Summary Synthesised Text
Singapore 21-12-2018      Summary Synthesised Text
Slovakia 20-09-2018      Summary Synthesised Text
Sweden 22-06-2018      Summary Synthesised Text
Ukraine 08-08-2019      Summary Synthesised Text
United Arab Emirates 29-05-2019      Summary Synthesised Text
United Kingdom 29-06-2018      Summary  Synthesised Text

    (*) A Synthesised Text was partly modified.

For more synthesized texts of the MLI provision and Japan's tax treaties [read]






Application of the MLI to Singapore's Tax Treaties - Synthesized Texts

  • Singapore-Australia CTA [read]
  • Singapore-Austria CTA [read]
  • Singapore-Ireland CTA [read]
  • Singapore-Japan CTA [read]
  • Singapore-Malta CTA [read]
  • Singapore-New Zealand CTA [read]
  • Singapore-United Kingdom CTA [read]





Application of the MLI to UK's Tax Treaties - Synthesized Texts

  • UK-Australia CTA [read]
  • UK-Canada CTA [read]
  • UK-France CTA [read]
  • UK-Finland CTA [read]
  • UK-Georgia CTA [read]
  • UK-India CTA [read]
  • UK-Ireland CTA [read]
  • UK-Japan CTA [read]
  • UK-Luxembourg CTA [read]
  • UK-Malta CTA [read]
  • UK-New Zealand CTA [read]
  • UK-Singapore CTA [read]
  • UK-Slovenia CTA [read]
  • UK-United Arab Emirates CTA [read]