The Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) entered into force for Canada, Switzerland, and Ukraine on 1 December 2019.
With respect to the covered agreements (tax treaties) between Canada and Ukraine and the 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 June 2020 in respect of other taxes (six months after entry into force). For Switzerland, however, certain reservations were taken regarding the entry into effect of the MLI. This includes that the reservation that the MLI will not be effective until additional internal procedures have been completed by Switzerland for each covered agreement and notification on the completion of the procedures is deposited.
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