One of the key planks of the OECD’s Base Erosion and Profit Shifting (BEPS) project is the adoption of new rules to limit treaty shopping, alongside improved dispute resolution arrangements. Both are minimum standards, which means that all countries in the BEPS Inclusive Framework must adopt them. Since these rules are built into double tax treaties, a Multilateral Convention is being adopted, which will effectively override existing bilateral agreements. So far 119 countries have joined the Inclusive Framework and it is required by the EU for a country to stay off its non-cooperative jurisdiction list.

There are 84 signatories to the Multilateral Convention with a further six having indicated their intention to do so, and 15 countries have ratified the Convention, which means it is (or shortly will be) in force in relation to them. These are Australia, Austria, France, Isle of Man, Israel, Japan, Jersey, Lithuania, New Zealand, Poland, Serbia, Slovak Republic, Slovenia, Sweden and the UK. In most cases, the effective date of the Convention is 1 January 2019, although in a few cases it is effective earlier. Once all 84 have ratified the Convention, over 1,400 double tax treaties will effectively be changed. The signing countries have brought a further 1,000 treaties with them, which will also be changed once the other parties ratify. There are currently about 3,000 double tax treaties, so coverage is very broad.