Abstract
The Multilateral (tax) Instrument (MLI) represents an exceptionally interesting international legal act that brings many novelties that will leave an impact both in the international tax regime and in international law in general and as such deserves our attention. Designed as a multilateral international legal act, the MLI aims to make changes within the network of about two thousand bilateral tax agreements, so that in a harmonized, unified and organized way, the latest recommendations of actions implemented under the auspices of the Organization for Economic Cooperation and Development are incorporated. (OECD), with the aim of combating the phenomenon of “base erosion and profit shifting” (BEPS) to jurisdictions with a low or non-existent tax (so-called “tax havens”). The MLI contains elements of modularity, giving Contracting Parties a wide range of options, but maintains consistency by insisting on the immutability of provisions aimed at achieving minimum standards. With such features, it can certainly represent a model for future multilateral agreements and, with its example, influence the further development of international law, which is the primary aspect of the interest of this paper.
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