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BEPS 2015:OECD plan to rewrite tax treaties into single rule by end 2017

The OECD has released the final measures on its two-year Base Erosion and Profit Shifting (BEPS) project to tackle tax avoidance by multinationals with plans to introduce a multilateral tax treaty merging all existing bilateral tax agreements while transfer pricing guidance is being rewritten and country by country tax reporting will be mandatory for assigned states by 2018

The aim is to finish negotiations on the multilateral instrument by the end of 2016, with representatives from 90 countries involved in the talks. The initial meeting of interested parties was held in June with the first convention to negotiate real treaty amendments scheduled for November 2015.

The new overarching rule would bring together up to 3,500 bilateral treaties.

Once the new measures become applicable, the expectation is that profits will be reported where the economic activities that generate them are carried out and where value is created.

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