ARTICLE · 04 NOVEMBER 2022

MLI Ratification

SNG Grant Thornton

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The MLI will not function in the same way as an amending protocol to a bilateral double tax agreement (DTA) which directly amends the text of the specific DTA. Instead,...

South AfricaTax

Raeesa Haneef-Danka

On 30 September 2022, South Africa deposited its instrument of ratification of the Multilateral Instrument (MLI) which will enter into force for South Africa on 1 January 2023.

The MLI will not function in the same way as an amending protocol to a bilateral double tax agreement (DTA) which directly amends the text of the specific DTA. Instead, it will apply alongside existing DTAs as it modifies their application in order to implement the OECD's Base Erosion Profit Shifting (BEPS) measures. Although the MLI will enter into force for South Africa on 1 January 2023, its entry into force for South Africa's covered agreements (tax treaties) will depend on the ratification of the MLI by the counterparty to a particular covered agreement.

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