It seems like your question is incomplete. However, if you're referring to the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) and its interaction with a specific tax agreement (e.g., a bilateral tax treaty), I can provide guidance on how the MLI modifies existing treaties.

What is the MLI?

The MLI is a multilateral treaty developed by the OECD as part of the BEPS Project. It allows countries to swiftly modify their existing bilateral tax treaties to implement anti-BEPS measures without renegotiating each treaty individually.

Synthesised Text of the MLI and a Tax Agreement

A synthesised text combines the provisions of an existing bilateral tax treaty with the modifications made by the MLI. This helps taxpayers and authorities understand how the treaty operates after MLI application.

Key Steps to Create a Synthesised Text:

1. Identify Covered Tax Agreements (CTAs):

   • Check if both treaty partners have listed the agreement under the MLI.
   • Confirm which provisions each country has adopted (reservations/notifications may apply).

2. Match MLI Modifications to Treaty Provisions:

   • The MLI modifies treaties by adding or replacing articles (e.g., Principal Purpose Test (PPT), Mutual Agreement Procedure (MAP), Limitation on Benefits (LOB)).
   • Example: If the original treaty lacks a PPT, the MLI may insert one.

3. Determine Entry into Effect:

   • The MLI’s changes apply based on each country’s ratification and domestic procedures.

Where to Find Synthesised Texts?

Many tax authorities (e.g., HMRC, OECD, IRS) publish synthesised texts for their treaties. For example:

• The OECD MLI Database provides matching details.
• Country-specific tax authorities may release consolidated versions.

If you’re looking for a synthesised text of a specific treaty, let me know the countries involved, and I can guide you further.

Would you like help interpreting a particular MLI provision or treaty modification?