On 19 September 2024, the Democratic Republic of the Congo signed the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (the BEPS Convention) at a signing ceremony held in Paris. The Democratic Republic of the Congo has become the 104th jurisdiction to join the landmark agreement to strengthen tax treaties, which now covers around 1950 bilateral tax treaties. This represents an important milestone in the implementation of treaty-related BEPS measures and the strengthening of the global tax treaty network.
Today, Azerbaijan deposited its instrument of ratification for the BEPS Convention, underlining their strong commitment to prevent the abuse of tax treaties and base erosion and profit shifting by multinational enterprises. The BEPS Convention will enter into force on 1 January 2025 for Azerbaijan.
As of today, 86 jurisdictions have either ratified, accepted, or approved the BEPS Convention resulting in the modification of over 1 400 treaties. Around 800 additional treaties will be modified once the BEPS Convention will have been ratified by all Signatories.
The BEPS Convention, negotiated by more than 100 countries and jurisdictions under a mandate from the G20 Finance Ministers and Central Bank Governors, is one of the most prominent results of the OECD/G20 BEPS Project. It is the world’s leading instrument for updating bilateral tax treaties and reducing opportunities for tax avoidance by multinational enterprises. Measures included in the BEPS Convention address treaty abuse, strategies to avoid the creation of a “permanent establishment”, and hybrid mismatch arrangements. The BEPS Convention also enhances the dispute resolution mechanism, especially through the addition of an optional provision on mandatory binding arbitration, which has been taken up by 33 jurisdictions.
The text of the BEPS Convention, the explanatory statement, background information, database, and positions of each signatory and parties are available at https://oe.cd/mli.