Covered Tax Agreement | Article 2 Decision Tree


For easy understanding of the applicability of Article 2(1)(a)(ii) of MLI, we present the decision tree diagram (flow chart). It is a quick summary of Article 2 of Multilateral Instrument.

As per Article 2(1)(a)(ii) of MLI, the MLI will modify only those double tax agreements that :

  • Each Party has specifically identified and listed in a notification to the Depository
  • As well as any amending or accompanying instruments to it
  • This is determined by title, names of the parties, date of signature, and, if applicable, at the time of notification (the date of entry into force).
Decision tree for Covered Tax Agreement Provisions Article 2 of MLI

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