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

International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2025

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

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.

Unlock this content.

The content you are trying to view is exclusive to our subscribers.

To unlock this content:

Take a Free Trial or Login
more across site & shared bottom lb ros

More from across our site

An EY survey of almost 2,000 tax leaders also found that only 49% of respondents feel ‘highly prepared’ to manage an anticipated surge of disputes
The international tax, audit and assurance firm recorded a 4% year-on-year increase in overall turnover to hit $11bn
Awards
View the official winners of the 2025 Social Impact EMEA Awards
CIT as a proportion of total tax revenue varied considerably across OECD countries, the report also found, with France at 6% and Ireland at 21.5%
Erdem & Erdem’s tax partner tells ITR about female leader inspirations, keeping ahead of the curve, and what makes tax cool
ITR presents the 50 most influential people in tax from 2025, with world leaders, in-house award winners, activists and others making the cut
Cormann is OECD secretary-general
Woldenberg is CEO of Chicago toymaking company Learning Resources
Lula, as he is commonly known, is Brazil’s president
Agarwal is director for indirect tax operations at shopping mall operator Majid Al Futtaim
Gift this article