Russia's Ministry of Finance recently clarified the application of the BEPS MLI to Russia's covered agreements (tax treaties), which entered into force for Russia on 1 October 2019. This includes that although the MLI entered into force on 1 October 2019, the earliest the MLI will apply for any of Russia's covered agreements will be 1 January 2021. This is because Russia made the reservation in accordance with article 35(7(a)) of the MLI, which provides that the MLI will not be effective unti…