Learning the instrument

Alison Lobb and Lisa Shipley examine the ‘multilateral instrument’ that could modify bilateral tax treaties efficiently and swiftly

The G20/OECD’s Base Erosion and Profit Shifting (‘BEPS’) project recognised at the outset that changes would be required to tax treaties to implement some of the measures to modernise the international tax system. Bilateral renegotiation of 3,000 or so existing tax treaties would take years to complete and therefore an important BEPS action would be to develop a ‘multilateral instrument’ that could modify bilateral tax treaties efficiently and swiftly.