Action 15: Developing a multilateral instrument to modify bilateral tax treaties

Many of the BEPS actions have resulted in agreed changes to the OECD Model Tax Convention. These changes must be implemented swiftly, efficiently and consistently to ensure that treaty-related BEPS issues can be addressed. The ordinary way for implementing such treaty changes would be for each country to renegotiate its existing bilateral tax treaties, which would take decades to complete given the size of the existing network of more than 3,000 tax treaties globally. The project therefore included a commitment to develop a multilateral instrument to sidestep this problem. Jesse Eggert and Evelyn Lio explain.