The Base Erosion and Profit Shifting (BEPS) initiative was introduced initially by the Organisation for Economic Co-operation and Development (OECD) in 2013 but later endorsed by the G20 in November 2015. It has had a significant impact on the global network of tax treaties. The introduction of the multilateral instrument has facilitated the swift implementation of numerous BEPS recommendations, allowing countries such as Indonesia, a member of the G20, to quickly modify their tax treaties without the need for extensive renegotiation that could take years to achieve. However, implementing these modifications has not been without its challenges.
The release of the multilateral instrument has resulted in simultaneous changes to multiple tax treaties, making it difficult for taxpayers to understand the resulting tax consequences. This can potentially lead to misunderstandings and incorrect business decisions. Furthermore, there are real challenges in implementing these changes, including the need for domestic legislation and the interpretation of ambiguous provisions in the multilateral instrument.