Are there MLI provisions for which the MLI offers no flexibility at all?

The MLI covers the treaty-related minimum standards that were agreed as part of the BEPS Package in November 2015 and to which all countries and jurisdictions within the Inclusive Framework on BEPS have committed. These minimum standards relate to the prevention of treaty abuse (BEPS Action 6) and the improvement of dispute resolution (BEPS Action 14). Where an MLI provision reflects an agreed BEPS minimum standard, a jurisdiction must meet the minimum standard when signing the MLI. Certain elements of these minimum standards can, however, be met in different ways provided for in the MLI.