The Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) entered into force for Belgium, India, and Russia on 1 October 2019.
With respect to the covered agreements (tax treaties) between Belgium and other countries for which the MLI has already entered into force, the MLI is generally effective from 1 January 2020 in respect of withholding taxes and for taxable periods beginning on or after 1 April 2020 in respect of other taxes (six months after entry into force).
For India and Russia, certain reservations were taken regarding the entry into effect of the MLI. India took the reservation that for its own application of the MLI in respect of withholding taxes, it will apply from the next taxable period beginning after 1 October 2019, i.e., 1 April 2020 for tax treaties with other countries for which the MLI has already entered into force. Russia took the reservation that the MLI will not be effective until additional internal procedures have been completed for each covered agreement and notification on the completion the procedures is deposited.
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