On 10 June 2026, the Netherlands published in the Official Gazette the Memorandum of Understanding (MoU) with Australia to establish the mode of application of the arbitration process provided for in Part VI of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). The MoU was signed by Australia and the Netherlands on 25 March 2026 and 28 May 2026, respectively, and is entered into pursuant to Article 24 (Mutual Agreement Proc…