On June 21, 2019, one year after it was tabled in the House of
Commons, Bill C-82, An Act to implement a multilateral
convention to implement tax treaty related measures to prevent base
erosion and profit shifting, received Royal Assent and became
law. By way of background, Canada had signed the Multilateral
Instrument (the "MLI") on June 7, 2017 and had then
announced its intention to adopt the minimum standards proposed by
the Organisation for Economic Co-operation and Development (the
"OECD") under the Base Erosion and Profit Shifting
project, as well as mandatory arbitration for tax treaty
disputes.
The next step for Canada is to notify the OECD through the
deposit of its instrument of ratification which is likely to be
done before the end of the year. The MLI will then enter into force
for Canada on the first day of the month following the expiration
of a three-month period from the date of notice to the OECD. For
example, if the notice is sent in October 2019,
