9 May 2019
Introduction of the Entry-into-Effect Date Article of the Multilateral Instrument under the BEPS Action 15
Part I- Introduction
Article 35(1) provides that the Multilateral Convention (the MLI) shall take effect in each contracting jurisdiction with respect to the covered tax agreement:
(a) for taxes withheld at source on amounts paid or credited to non-residents (withholding tax), where the events giving rise to such taxes occurs on or after the first day of the next calendar year that begins on or after the latest of the dates on which the MLI comes into force for each of the contracting jurisdictions to the covered tax agreement (the CTA); and
(b) with respect to all other taxes leived by that contracting jurisdiction, for taxes levied with respect to taxable periods beginning on or after an expiration of a period of 6 calendar months from the latest of the dates on which the MLI comes into force for each of the contracting jurisdictions to the CTA.
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