BEPS Action 15: Developing a Multilateral Instrument to Modify Bilateral Tax Treaties

The final action of the BEPS plan, Action 15, is titled "Developing a Multilateral Instrument to Modify Bilateral Tax Treaties".

The BEPS Action Plan introduces numerous measures to prevent and combat cross-border tax avoidance while also strengthening the protection of taxpayer rights. However, how can these measures be effectively implemented in practice? Having a plan is not enough—combating cross-border tax avoidance requires embedding these measures into the legal frameworks of each country or region.

The international tax legal framework consists of two main components: domestic law and international law. In the realm of tax, international law is primarily represented by bilateral tax treaties. Many of the anti-tax avoidance measures in the BEPS Action Plan are designed to be implemented through amendments to bilateral tax treaties. Since the vast majority of tax treaties worldwide are based on the OECD Model Tax Convention, the OECD, as the driving force behind BEPS, can guide countries on how to amend their bilateral treaties to ensure the effective implementation of the action plans.