MLI Big Picture Changes Update

The Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting ("MLI") is a multilateral treaty created by the Organization for Economic Co-operation and Development ("OECD") that modifies bilateral tax treaties between participating jurisdictions to implement international tax rules and lessen the opportunity for tax avoidance by multinational enterprises.

The MLI was released on November 24, 2016 and 84 jurisdictions have already joined the MLI, which now covers over ¹,400 bilateral tax treaties.1 Notably, the United States did not sign the MLI.

On June 7, 2017, Canada signed the MLI. On May 28, 2018, Canada introduced a Notice of Ways and Means Motion² to introduce an Act to Implement the MLI in Canadian law. Within a month, on June 20, 2018, Bill C-82³, called Multilateral Instrument in Respect of Tax Conventions Act, was introduced. Bill C-82 has had Second Reading and has been referred to the Standing