BEPS Action 15 – Develop a Multilateral Instrument

BEPS Action 15 “Developing a multilateral instrument to modify bilateral treaties” aims to develop a multilateral instrument to enable jurisdictions to implement measures developed in the course of the work on BEPS and to amend bilateral tax treaties.

The multilateral instrument should be open for signature by the end of 2016 by any interested jurisdiction.

The Final Report on BEPS Action 15 concludes that a multilateral instrument to implement the BEPS treaty-related measures and amend bilateral tax treaties is desirable and feasible, and that negotiations for such an instrument should be convened quickly. At the time of release of the Final Report on BEPS Action 15, approximately 90 countries were participating in the development of the multilateral instrument, for probable signature in 2016.

Australia’s response

Australia is a member of the group convened to develop the multilateral instrument. The inaugural meeting of the group took place in November 2015.