On 30 September 2024, Mongolia deposited its instrument of ratification for the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (BEPS Convention), which now covers around 1950 bilateral tax treaties, underlining its strong commitment to prevent the abuse of tax treaties and base erosion and profit shifting (BEPS) by multinational enterprises. The BEPS Convention will enter into force on 1 January 2025 for Mongolia.

Today, Germany confirmed the completion of its internal procedures for the entry into effect of the provisions of the BEPS Convention. Also, Croatia, Greece, Hungary, Malta, Slovak Republic and Spain have made notifications to apply a shorter period for the entry into effect of the provisions of the BEPS Convention with respect to their treaty with Germany, bringing forward the benefits of the BEPS Convention.

As of today, 87 jurisdictions have either ratified, accepted, or approved the BEPS Convention resulting in the modification of over 1500 treaties. Around 450 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.