As previously reported, South Africa deposited on 30 September 2022, its instrument of ratification for the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). The OECD has now published South Africa's definitive list of reservations and notifications for the MLI that was made upon deposit of the ratification instrument. The definitive position is in line with the initial position made when South Africa signed the MLI. Based on the date of deposit, the MLI will enter into force for South Africa on 1 January 2023, although its entry into force for South...