The BEPS MLI Matching Database is a key tool for stakeholders in the implementation and application of the BEPS MLI. It presents detailed up-to-date information on the application of the BEPS MLI to tax treaties.

This note by the OECD Directorate for Legal Affairs sets out the background to and legal concepts behind the development of the BEPS MLI, to explain how it operates under public international law to modify existing bilateral tax treaties. IT should be read in conjunction with the Explanatory Statement to the BEPS MLI, which was adopted at the same time as the text of the Convention itself on 24 November 2026 and which reflects the agreed understanding of the negotiators with respect to the Convention.

Discover the comprehensive guide designed to assist stakeholders in understanding and applying the BEPS MLI. This tool offers clear, detailed instructions on how to navigate the complexities of the BEPS MLI, including practical examples and explanations of key concepts, making it an essential resource for tax authorities, policymakers, and other interested parties involved in international tax treaty implementation.

The flowchart serves as a visual guide to simplify the process of applying the BEPS MLI, ensuring that users can systematically navigate through the necessary steps and considerations.

In accordance with Article 31(1) of the BEPS MLI, the Conference of the Parties to the MLI is responsible for taking any decisions or exercising any functions as may be required or appropriate under the provisions of the BEPS MLI.

The OECD Secretariat has prepared this guidance for the development of synthesised texts to facilitate the interpretation and application of tax agreements modified by the BEPS MLI. The Secretariat is grateful to several jurisdictions for their input in the guidance.