UK and International Tax news

Antigua and Barbuda Sign Multilateral BEPS Convention

Friday 20th June 2025

The OECD/G20 Inclusive Framework on BEPS has announced that Antigua and Barbuda has signed the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (the BEPS Convention).

Antigua and Barbuda become the 105th jurisdiction to join the landmark agreement to strengthen tax treaties, which now covers around 2000 bilateral tax treaties. This represents an important milestone in the implementation of treaty-related BEPS measures, with the strengthening of the global tax treaty network.

89 jurisdictions have either ratified, accepted, or approved the BEPS Convention, resulting in the modification of over 1600 treaties. Around 400 additional treaties will be modified once the BEPS Convention will have been ratified by all signatories.

The BEPS Convention, negotiated by more than 100 countries and jurisdictions, is one of the most prominent results of the G30 BEPS Project. It is the world’s leading instrument for updating bilateral tax treaties and reducing opportunities for tax avoidance by multinational enterprises.

The BEPS Action Plan identified 15 actions to address BEPS and set deadlines to implement those actions. Action 15 provided for the development of a multilateral instrument to modify bilateral tax treaties.

The Multilateral Instrument allows governments to modify existing bilateral tax treaties in a synchronised and efficient manner to implement the tax treaty measures developed during the BEPS Project, without the need to expend resources renegotiating each treaty bilaterally.

Measures included in the BEPS Convention/MLI address treaty abuse, strategies to avoid the creation of a “permanent establishment”, and hybrid mismatch arrangements. The BEPS Convention also enhances the dispute resolution mechanism, especially through the addition of an optional provision on mandatory binding arbitration, which has been taken up by 34 jurisdictions.

The BEPS Convention [Multilateral Instrument] entered into force on 1 July 2018 and its provisions entered into effect for the first provisions on 1 January 2019.

If you would like more information on the above, please contact Keith Rushen on 0207 486 2378.

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