On 30 November 2023, UK HMRC published a Memorandum of Arrangement (MOA) signed with New Zealand on the implementation of Part VI of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). Part VI of the MLI allows jurisdictions choosing to apply it to adopt mandatory binding arbitration for the resolution of tax treaty disputes. The MOA was signed by New Zealand on 11 October 2023 and by the UK on 2 October 2023 and is effective on the later of the two signature dates.