The Australian Taxation Office (ATO) has published a Memorandum of Understanding signed with the United Kingdom on 21 May 2021 concerning the mode of application on the implementation of Part VI (Arbitration) of the BEPS MLI. This includes sections on arbitration requests, minimum information requirements, the appointment of arbitrators, the arbitration process, etc. The Memorandum of Understanding takes effect on 21 May 2021 and remains in effect until terminated by either competent authori…