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Inland Revenue

Tax Policy

Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (the MLI)

Text: OECD website
Status: In force for New Zealand
Signed: 8 June 2017 [7 June 2017 in Paris, France]
In force: For New Zealand: 1 October 2018
Effective:

The MLI will come into effect under Article 35(1) for a DTA from the latest of the dates on which the MLI enters into force for New Zealand and the other jurisdiction:

  • for withholding taxes: from 1 January of the following calendar year; and
  • for all other taxes: for taxable periods commencing on or after the expiry of six calendar months.
Legislation:

Double Tax Agreements (Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting) Order 2018 (New Zealand Legislation website)

National interest
analysis:
Finance and Expenditure Committee report (includes NIA) (PDF 95 KB) (New Zealand Parliament website)
Additional information:

OECD information

Synthesised texts - we are progressively adding these to the treaty partner pages as they are completed.

Covered tax agreements

Treaty partner Details
Australia MLI entered into force for Australia on 1 January 2019
Belgium MLI entered into force for Belgium on 1 October 2019 
Canada MLI entered into force for Canada on 1 December 2019
Chile MLI entered into force for Chile on 1 March 2021
Czech Republic MLI entered into force for Czech Republic on 1 September 2020
Denmark MLI entered into force for Denmark on 1 January 2020
Finland MLI entered into force for Finland on 1 June 2019
France MLI entered into force for France on 1 January 2019
Hong Kong MLI entered into force for Hong Kong on 1 September 2022
India MLI entered into force for India on 1 October 2019
Indonesia MLI entered into force for Indonesia on 1 August 2020
Ireland MLI entered into force for Ireland on 1 May 2019
Japan MLI entered into force for Japan on 1 January 2019
Korea MLI entered into force for Korea on 1 September 2020
Malaysia MLI entered into force for Malaysia on 1 June 2021
Mexico MLI entered into force for Mexico on 1 July 2023
Netherlands MLI entered into force for Netherlands on 1 July 2019
Poland MLI entered into force for Poland on 1 July 2018
Singapore MLI entered into force for Singapore on 1 April 2019
South Africa MLI entered into force for South Africa on 1 January 2023
Spain MLI entered into force for Spain on 1 January 2022
Sweden MLI entered into force for Sweden on 1 October 2018
Thailand MLI entered into force for Thailand on 1 July 2022
United Arab Emirates MLI entered into force for United Arab Emirates on 1 September 2019
United Kingdom MLI entered into force for the United Kingdom on 1 October 2018

Related information