The multilateral instrument – called the MIL - will embody all the key measures in the BEPS action plan, amid fears that decisions such as the European Commission’s state aid ruling regarding Ireland’s tax agreements with Apple risk undermining the OECD push for common agreements on tax standards.

The MIL will sit ‘on top’ of existing bilateral tax agreements and will implement what Jesse Eggert, head of the OECD’s tax policy and statistics division, called the ‘core’ of BEPS, that is the actions on treaty abuse, hybrid mismatches, permanent establishment status, and dispute resolution.

‘The approach is flexible, so countries will be able to opt in to some areas, for example agreeing to arbitration, and in others will be able to opt out and continue to use bilateral negotiations. But there are minimum standards which must be adhered to,’ Eggert said.