BEPS Multilateral Instrument (MLI)
In September 2020, Albania, Bosnia and Herzegovina, Costa Rica, and Jordan deposited their instruments of ratification of the MLI with the OECD and confirmed their preliminary positions regarding the PE provisions. At the same time, Albania and Costa Rica removed certain tax treaties from their list of Covered Tax Agreements (CTAs). With respect to the PE positions, all these jurisdictions have adopted Article 12 (Agency PE) and Article 15 (Definition of closel…