[2] Canada, Department of Finance, “Notice of Ways and Means Motion to introduce an Act to Implement a Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting” (May 2018), online: Department of Finance: . [6] Ministry of Foreign Affairs, “Trade and Development, Status of Reserve List and Notifications at signing” (30 May 2017), online: OECD . [11] Canada, Department of Finance, Backgrounder: The Next Step in the Fight Against Aggressive International Tax Avoidance (May 28, 2018): online: <Department of Finance . The MLI applies to Canadian tax treaties that are covered by the MLI. A tax treaty is covered by the MMA if each party has listed this contract for the purposes of the MMA and has implemented the LML. The MLI will enter into force for Canada on December 1, 2019 and will come into force for any specific tax treaty covered, in accordance with Section 35 of the ACCORD. The MLI will apply to some of Canada`s tax treaties effective January 1, 2020. The MLI will not affect Canada`s tax treaties with the United States (which have not signed the LMLI) and with Germany and Switzerland (with whom Canada has announced bilateral negotiations). Other Canadian tax treaties not covered by the MLI are Equador, Guyana, Kyrgyzstan, Taiwan, Uzbekistan and Venezuela.

[5] Canada, Department of Finance, “Canada Ratifis the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting” (August 29, 2019): online: Department of Finance . The MLI will have a significant impact on the tax treatment of many cross-border agreements. Canada`s commitment to the MLI requires companies to think proactively and anticipate transactions that may occur in the near future to ensure compliance with the new requirements; Otherwise, the MLI could result in a denial of benefits under Canada`s bilateral tax treaties, which could result in a much higher tax burden. The Multilateral Agreement for the Implementation of Measures to Prevent Erosion and Profit Transfer (MLI) is a multilateral treaty established by the Organisation for Economic Co-operation and Development (OECD). The MLI amends bilateral tax treaties between participating jurisdictions to implement international tax rules and reduce the possibility of tax evasion by multinationals. In addition to these minimum standards, participating jurisdictions have been entitled to apply or exclude other provisions. When Canada signed the LML, it submitted an interim list of reservations with respect to the optional provisions. The final stage by which the MLI would enter into force in Canada was completed on August 29, 2019, when Canada tabled its ratification instrument with the OECD. As soon as the ratification instrument is introduced, the MLI for Canada will come into force on December 1, 2019. The MLI will come into force on January 1, 2020 for certain Canadian tax treaties, including tax agreements with France and the United Kingdom.

The text of the Multilateral Instrument (II) and its explanatory statement were drawn up in negotiations involving more than 100 countries and jurisdictions and adopted on 24 November 2016 as part of a mandate given by G20 finance ministers and central bank governors at their February 2015 meeting.