Global Daily Tax News, Brazil Signs Up To The BEPS MLI, (Oct 22, 2025)

On October 20, 2025, Brazil signed up to the BEPS multilateral instrument, becoming its 106th signatory.

So far, 90 jurisdictions have either ratified, accepted, or approved the BEPS Convention resulting in the modification of over 1,600 treaties. Around 400 additional treaties will be modified once the BEPS Convention has been ratified by all signatories.

The MLI enables countries to modify their existing tax treaties to include measures developed under the OECD/G20 BEPS Project without having to individually renegotiate these treaties.

The instrument will implement minimum standards to counter treaty abuse, prevent the artificial avoidance of permanent establishment status, neutralize the effects of hybrid mismatch arrangements, and improve dispute resolution.

Jurisdictions may choose, when signing the BEPS MLI, which of their treaties they wish to amend through the MLI. These treaties are known as "covered agreements". Brazil has so far selected 26 double tax treaties as covered agreements. This list will be confirmed when the country ratifies the BEPS MLI.

The BEPS MLI will come into effect for Brazil's treaties from the first day of the fourth month following the country depositing its instrument of ratification with the OECD.