Even though Liechtenstein and Austria are both parties to the Multilateral Instrument (MLI), their bilateral tax treaty has not been notified as a “covered tax agreement" and is hence not covered by the MLI. This is because the tax treaty has been brought in line with the BEPS minimum standard prior to the MLI through a 2016 protocol. Georg Kofler analyzes the tax treaty between Austria and Liechtenstein in light of the 2016 protocol, its relation to the MLI, and the mode the BEPS minimum standard was implemented.
