As of June 21, 2019, Canada has enacted into law the
OECD-sponsored Multilateral Convention to Implement Tax Treaty
Related Measures to Prevent Base Erosion and Profit Shifting
(MLI). This enactment represents the penultimate step in the
domestic ratification of the MLI in Canada, which will be completed
by the issuance of an order in council authorizing the signing of
the instrument of ratification. Canada is expected to notify the
OECD within the next few months that it has ratified the MLI.
As ratification and notification are essentially formalities,
the MLI may enter into effect with respect to those of Canada's
bilateral tax treaties designated as "covered tax
agreements" (CTAs) as early as January 1, 2020, for
withholding tax purposes and April 1, 2020, for tax years beginning
on that date, for all other purposes.
