Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting ("MLI")

In line with Singapore's commitment to implement the minimum standard on preventing treaty abuse, Singapore has participated in the negotiation of the MLI. The MLI is intended to allow jurisdictions to swiftly amend their tax treaties to implement the tax treaty related Base Erosion and Profit Shifting (BEPS) recommendations. The MLI also improves on the dispute resolution mechanisms. 

Date What's new
 1 April 2019

The MLI entered into force for Singapore.

The amendments made by the MLI to Singapore's DTAs with Australia, Austria, France, Isle of Man, Israel, Japan, Jersey, Lithuania, Malta, New Zealand, Poland, Slovak Republic, Slovenia and the United Kingdom took effect on this day. Details of these amendments can be found here.

21 December 2018

Singapore deposited its instrument of ratification for the MLI. The MLI will enter into force for Singapore on 1 April 2019.

Read the press release.

1 July 2018The MLI entered into force after the deposit of instruments of ratification by five jurisdictions.
7 June 2017

Singapore signed the MLI at the first signing ceremony held in Paris. 

Read the press release

24 November 2016 (Paris time)

More than 100 jurisdictions (including Singapore) concluded the negotiation of the MLI.

Read more on the text of the MLI (277KB) and the explanatory statement to the MLI (557KB).


Interaction between the MLI and tax agreements

At the point of ratification of the MLI on 21 December 2018, the list of DTAs that Singapore intends to amend using the MLI can be found here (135KB). These DTAs will only be amended if Singapore's treaty partners also choose to amend the DTAs using the MLI. DTAs that will be amended by the MLI are referred to as Covered Tax Agreements under the MLI.

Signatories to the MLI may choose the provisions in the MLI to adopt and how such provisions should be adopted. A Covered Tax Agreement will be amended only if both treaty partners share the same position on the provisions of the MLI. The agreed changes to a Covered Tax Agreement will enter into effect after the treaty partner has also ratified the MLI. Singapore's positions on the MLI provisions can be found here (355KB).

View the list of DTAs that Singapore and other jurisdictions would like to amend using the MLI as well as the positions that Singapore and the other jurisdictions have adopted for the MLI.

Guidance on the MLI

Please view the FAQs (368KB).