Developing a Multilateral Instrument to Modify Bilateral Tax Treaties, Action 15 - 2015 Final Report

In series:OECD/G20 Base Erosion and Profit Shifting Projectview more titles

Published on October 05, 2015

Also available in: French


Drawing on the expertise of public international law and tax experts, this report explores the technical feasibility to develop a multilateral instrument to modify tax treaties so as to efficiently implement the tax treaty-related BEPS measures. The report concludes that such an instrument is desirable and feasible and that negotiations for the multilateral instrument should be convened quickly. Based on this analysis, a mandate has been developed for an ad-hoc group, open to the participation of all countries on an equal footing, to develop the multilateral instrument and open it for signature in 2016.





Join the discussions with senior members from the OECD's Centre for Tax Policy and Administration on the final outputs of the OECD/G20 Base Erosion and Project Shifting Project, including the next steps and the involvement of developing countries. 

  • A live press conference for journalists at 2:00-3:00 PM, CEST (Paris, GMT +01:00) with Pascal Saint-Amans, Director, CTPA.
  • A live BEPS webcast for tax experts at 4:00-5:30 PM, CEST (Paris, GMT +01:00) with senior members of CTPA.



Base Erosion and Profit Shifting (BEPS) refers to tax planning strategies that exploit gaps and mismatches in tax rules to artificially shift profits to low or no-tax locations where there is little or no economic activity, resulting in little or no overall corporate tax being paid.