On 5 March 2019, the Dutch upper house of parliament approved the ratification of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI), including amendment of the provisional list of reservations and notifications that was earlier approved by the lower house of parliament. This includes that with respect to MLI Article 12 (Artificial Avoidance of Permanent Establishment Status through Commissionnaire Arrangements and Similar Strategies), the Netherlands will reserve the right for the entirety of the Article not to apply to its covered tax agreements. Once the ratification process is complete, the Netherlands...