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.  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: .  Canada, Department of Finance, Backgrounder: The Next Step in the Fight Against Aggressive International Tax Avoidance (May 28, 2018): online: <Department of Finance .  Ministry of Foreign Affairs, “Trade and Development, Status of Reserve List and Notifications at signing” (30 May 2017), online: OECD . 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.  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 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. . The MLI is a multilateral agreement that will implement a series of tax convention measures aimed at reducing the tax evasion opportunities of multinationals. On June 7, 2017, Canada became the signatory of the MLI.
On May 28, 2018, Canada announced its intention to amend its reserve list to raise reservations on some of the optional provisions for dividends (Article 8), capital gains (Article 9), double tie-break residence rules (Article 4) and double taxation exemption (Article 5). In particular, Canada proposed that Canada today table its ratification instrument with the custodian of the Multilateral Convention for the Implementation of Measures to Prevent Base Erosion and Profit Transfer (the Multilateral Instrument or the “MLI”). The MLI is still open to other signatories. Legal systems interested in signing the AML are invited to contact the OECD secretariat.