Currently, the way the convention works is that on signature, countries deposit a provisional list of tax treaties to which they would like this convention to apply. On signature, Canada provisionally listed 75 tax treaties. It is expected that on ratification this number would increase to 84, because the basis on which the list was developed was that it would include all countries participating in the inclusive framework on BEPS, namely the countries that are engaged in this work and have therefore indicated a willingness and a desire to sign this convention. Also, the countries that are part of the inclusive framework are those that have been identified by peer countries as being at risk for base erosion and profit shifting.
The countries that have not been covered are Switzerland and Germany. The reason for these two not being covered is that on the day Canada signed the multilateral convention, the government also simultaneously announced that bilateral negotiations had commenced with the two countries. The expectation is that these two tax treaties will be updated on a bilateral basis.