The OECD’s project on Base Erosion and Profit Shifting (“BEPS”), among others, includes tax treaty-related measures to address certain hybrid mismatch arrangements, prevent treaty abuse, address artificial avoidance of permanent establishment status, and improve dispute resolution. Recognizing the need for an effective mechanism to implement changes on these topics in a synchronized and efficient manner across the vast network of existing bilateral tax treaties, the OECD released the text of the “Multilateral Convention to Implement Tax Treaty Related Measures To Prevent Base Erosion and Profit Shifting” on 24 November 2016 as part of BEPS Action Plan 15.1.
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