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HMRC’s proposed changes to the MLI

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HMRC has published guidance on the proposed changes to the provisional list of UK reservations and notifications under the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (the multilateral instrument or MLI) as made when it was signed on 7 June 2017.

The revisions:

  • amend errors in the original notifications;
  • list agreements that were omitted from the original list in error;
  • list agreements that have been signed since signature of the MLI; and
  • remove from the list agreements where it has been agreed that modifications will be made through bilateral arrangements.

The revisions are currently in draft, the final list of reservations and notifications will be submitted to the OECD once the UK has completed its ratification procedures.

The UK signed the MLI in June 2017 and introduced legislation in FA 2018 to implement it fully into UK law. A draft order giving effect to the BEPS multilateral convention in UK legislation was published on 28 March 2018.