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French Tax Authority Publishes Guidelines on BEPS MLI Application

22 December 2020

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Treaty Development

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France-OECD

The French tax authority has published guidelines on the application of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). France deposited its instrument of ratification for the MLI on 26 September 2018 and it entered into force for the country on 1 January 2019, although the MLI's application to France covered agreements (tax treaties) depends on the ratification of the MLI by the counterparty to a particular covered agreement. The MLI guidelines cover the general principles for the application of the MLI, as well as specific options (reservations and notification) chosen...