How does the MLI introduce mandatory binding arbitration into more than 150 treaties?

The MLI introduces the MAP arbitration provisions that are included in Part VI of the MLI into treaties concluded by Parties opting in for these provisions. It is expected that the provisions will apply to more than 150 existing treaties. This ensures that taxpayers that initiate a case under the mutual agreement articles procedure of these treaties will be certain that their cases will be resolved and double taxation will be eliminated in accordance with the treaty.