Centre for Tax Policy and Administration
Developing a Multilateral Instrument to Modify Bilateral Tax Treaties
This report identifies the issues arising from the development of a multilateral instrument
that modifies bilateral tax treaties. Without a mechanism for swift implementation,
changes to model tax conventions only widen the gap between the content of these models
and the content of actual tax treaties. Developing such a mechanism is necessary not
only to tackle base erosion and profit shifting, but also to ensure the sustainability
of the consensual framework to eliminate double taxation. This is an innovative approach
with no exact precedent in the tax world, but precedents for modifying bilateral treaties
with a multilateral instrument exist in various other areas of public international
law. Drawing on the knowledge of experts in public international law and taxation,
the Report concludes that a multilateral instrument is desirable and feasible, and
that negotiations for such an instrument should be convened quickly.
Published on September 16, 2014Also available in: German, French, Korean, Chinese
In series:OECD/G20 Base Erosion and Profit Shifting Projectview more titles