In this article, the author discusses the ways in which the OECD’s BEPS Action 15 multilateral instrument may be adopted and interpreted in India. The author sets out the status of the instrument under the Indian Constitution, its interaction with domestic law and existing tax treaties, and the aids available to the courts for its interpretation. In this context, the article canvasses challenges faced by India arising from its OECD non-member observer status and its reservations in the OECD Commentary to certain interpretations of the language of the OECD model treaty.