(1) Section 826 of the Principal Act is amended by inserting after subsection (1D) the following:

"(1E) Where -

(a) the Government by order declare -

(i) that it has become a signatory to the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (in this section referred to as the ‘Multilateral Convention’) which was done at Paris on the 24th day of November 2016, for the purposes of the modification of arrangements of the type specified in subsection (1), such that -

(I) the extent to which the Government wishes to modify each such arrangement is specified in full in the reservations and notifications made to the Secretary-General of the Organisation for Economic Co-operation and Development (in this section referred to as ‘the Depository’) in accordance with the Multilateral Convention,

(II) any such arrangement may only be modified where the government of the territory outside the State with which the arrangement has been made has completed its own internal ratification procedures in relation to the Multilateral Convention and has notified that arrangement to the Depository, and