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New Zealand Corrects BEPS MLI Position in Regard to Tax Treaties with Hong Kong and South Africa

22 June 2023

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Treaty Development

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New Zealand-Hong Kong-South Africa-OECD

The OECD has published a corrected MLI position deposited by New Zealand on 20 June 2023, including two changes regarding the tax treaties with Hong Kong and South Africa. With regard to the 2010 tax treaty with Hong Kong, the amending protocol to the treaty signed in 2017 is added to the MLI position. With regard to the 2002 tax treaty with South Africa, it is added that paragraph 2(b)(i) of Article 10 (Dividends) of the treaty is not subject to the reservation regarding Article 8 of the MLI. This means that the 365-day holding period condition of the MLI...