A Multilateral Instrument for Updating the Tax Treaty Network

A Multilateral Instrument for Updating the Tax Treaty Network
This IBFD book gives you an overview of the key aspects of the Multilateral Instrument, which is seen as the most far-reaching development in international tax law in decades. It’s a concise and in-depth analysis of the Multilateral Instrument and its impact on the tax treaty network through the implementation of the treaty-related BEPS measures. Written by leading expert Nathalie Bravo, it lets you gain the information you need about this complex but important topic.

Why this book?

The Multilateral Instrument is changing the landscape of international tax law. It is modifying over 1,200 tax treaties with a view to coordinating the implementation of international tax rules to avoid base erosion and profit shifting (BEPS) and reducing the negative effects of harmful tax competition among states. Signatory countries can incorporate the rules from the OECD BEPS Project into their tax treaty network. These rules encompass hybrid mismatch arrangements, the abuse of treaties and the artificial avoidance of permanent establishment status and rules for improving dispute resolution mechanisms, including mandatory binding arbitration.

A Multilateral Instrument for Updating the Tax Treaty Network provides a systematic analysis of the Multilateral Instrument from a public international law and tax perspective. You’ll learn how the Multilateral Instrument works, how it impacts tax treaties and the extent to which parties and signatories have committed to implementing the uniform tax treaty-related BEPS measures through this instrument.

You’ll find this book to be a valuable resource, whether you’re an academic, tax professional, international organization official, government official or tax judge.


  • Gain a full-frame picture of the Multilateral Instrument through this detailed legal analysis
  • Be guided through the key elements of the Multilateral Instrument from concept to interaction with other tax agreements and from the flexibility of the instrument to potential future changes


Sample excerpt, including table of contents

This book is part of the IBFD Doctoral Series

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Nathalie Bravo is currently a tax adviser for international tax law and transfer pricing at PwC in Vienna, Austria. She completed the Doctoral Program in International Business Taxation (DIBT) at the Institute for Austrian and International Tax Law of the Vienna University for Economics and Business (WU Vienna) with honours. Her doctoral project titled “A Multilateral Instrument for Updating the Tax Treaty Network” was awarded with the DOC Fellowship of the Austrian Academy of Sciences. The dissemination of the preliminary results of her PhD research allowed Nathalie to conduct an internship at the OECD, where she contributed to the work under Action 15 to develop a multilateral instrument to implement tax treaty-related BEPS measures. Nathalie also obtained an LLM in International Tax Law from WU Vienna with honours and received her law degree from the Universidad Católica Andrés Bello in Caracas, Venezuela.

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