The Inland Revenue Board of Malaysia (IRBM) has published the synthesized text of the Malaysia–Spain double tax treaty as modified by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI).
The synthesized text consolidates the treaty's provisions with the MLI modifications that apply between the two countries, based on the reservations and notifications each country submitted to the OECD as Depositary. It is intended as a practical reading aid. The IRBM makes clear that the authentic legal texts of the underlying treaty and the MLI itself take precedence and remain the operative legal instruments.
Practitioners working on Malaysia–Spain cross-border structures should consult the synthesized text to understand which MLI provisions have taken effect between the two jurisdictions, while bearing in mind that any legal dispute will be resolved by reference to the original treaty and MLI texts rather than the synthesized version.