The Australian Taxation Office has published a Memorandum of Understanding (MoU) signed with Belgium on 3 March 2021 to establish the mode of application of the arbitration process provided for in Part VI of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). The MoU has been entered into pursuant to Article 25 (Mutual Agreement Procedure) of the 1977 income tax treaty between the two countries as amended by the MLI. It cove…