What Does the MLI Actually Do for PEs?

Article by: Johann Müller – First published on KluwerTaxBlog

Denmark accepted all MLI articles dealing with PEs, but what does that actually mean?  Reading the MLI itself leaves one somewhat bewildered, being thrown back and forth between a variety of articles and options.  Reading the instrument of ratification, does not necessarily help: it tends be a collection of long list of countries with treaty articles, interspersed by texts typically starting with “Pursuant to article x of the Convention, Denmark considers that the following agreements contain a provision described in article y”.

So, to bring this closer to the ground, I shall go through those articles in the MLI specifically mentioning PEs and elaborate on what it is that they do. Denmark has as part of the ratification of the MLI decided to opt into all parts of the MLI also all non-compulsory provisions. This is a significant change from when Denmark originally signed the MLI.

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