Changes to the OECD Model Tax Convention are intended to
ultimately produce changes to the network of bilateral tax treaties that
form a key component of the broader international tax architecture.
G20 Leaders endorsed the BEPS Action Plan, and committed to take the
necessary individual and collective actions in order to tackle BEPS. The 15
BEPS Action Plan deliverables span three different areas: recommendations
for domestic law taking the form of best practices and model domestic
rules, other reports, as well as changes to the OECD Model Tax Convention
and internationally agreed guidance on implementation. Tax treaty-related
issues are agreed to be a key focus of BEPS concerns. The development of a
multilateral instrument to tackle these treaty-based BEPS issues first of all
requires agreement on the substance of the tax treaty measures required to
respond to BEPS. Working groups are making steady and important progress
towards this goal. Indeed, the first outputs are being made public at the same
time as this report, while other outputs are expected by 2015.