On 29 March 2019, the Netherlands deposited the ratification instrument for the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI), including on behalf of Curaçao. Based on the date of deposit, the MLI will enter into force for the Netherlands and Curaçao on 1 July 2019, although its entry into force for particular covered agreements (tax treaties) will depend on the ratification of the MLI by the counterparty to a covered agreement.
The MLI will generally enter into force for a particular covered agreement on the first day of the month following a three-month period after both parties to the covered agreement have deposited their ratification instruments. Once in force, the provisions of the MLI will generally apply for a covered agreement from 1 January of the year following its entry into force in respect of withholding taxes, and for all other taxes with respect to taxable periods beginning on or after the expiration of a 6-month period following the date of entry into force.
Click the following links for the Netherlands's definitive list of reservations and notifications and Curaçao's definitive list of reservations and notifications.
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