The multiple amendment of bilateral double taxation conventions

By any measure, the OECD Model Tax Convention on Income and on Capital is a phenomenal success, but with this success comes a major problem: how to improve upon the wording that has become standard in so many bilateral tax treaties. One of the most pressing problems in international tax practice is how to devise a simple system - consistent with the bilateral nature of existing treaties and the constitutional traditions of the many countries concerned - for amending the wording of many bilateral treaties in a short period of time. This article looks at some possible solutions to this problem and proposes that the OECD adopt multilateral framework agreements for amending existing treaties.