The Australian Taxation Office has published a Memorandum of Understanding (MoU) signed with Japan 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 is entered into pursuant to Article 27 (Mutual Agreement Procedure) of the 2008 tax treaty between the two countries as modified by Article 16 and paragraph 10 of Article 19 of t…