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"). The MLI modifies bilateral tax
treaties between participating jurisdictions to implement
international tax rules, and to lessen the opportunity for tax
avoidance by multinational enterprises.
The MLI was released on November 24, 2016, and it already covers
94 jurisdictions.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-82,3 called Multilateral
Instrument in Respect of Tax Conventions Act, was introduced. On
June 21, 2019, Bill C-82 received Royal Assent,4 and on
August 29, 2019, Canada deposited its instrument of ratification
with
