OECD – Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting: Entry into effect under Article 35(1)(a). Note by the OECD Secretariat. 1. This note, prepared with the assistance of the OECD Directorate for Legal Affairs, seeks to clarify the interpretation and application of Article 35 of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (the MLI) on the entry into effect of the provisions of the MLI. 2. The question which has arisen on Article 35(1)(a) is this: when will the MLI have effect for taxes withheld at source where the latest of the dates of entry into force of the MLI for a pair of Contracting Jurisdictions is on 1 January of a given calendar year?(…)
