Skip to main content
Inland Revenue

Tax Policy

PUBLISHED 28 November 2016

OECD releases text of multilateral instrument to counter base erosion and profit shifting

As part of the global fight against base erosion and profit shifting, the OECD in conjunction with around 100 jurisdictions including New Zealand has developed a multilateral instrument that will amend double tax agreements between nations around the world. The OECD has now released the text of that instrument and the Government expects to sign it in 2017. Officials intend to consult on implementation of the multilateral instrument in the coming months. For more information see the media statements from the Minister of Revenue and OECD.

Hon Michael Woodhouse
Minister of Revenue

Media statement

28 November 2016

OECD multilateral instrument to counter BEPS

Revenue Minister Michael Woodhouse today welcomed the release of the OECD’s new multilateral instrument – the latest step in the global fight against base erosion and profit shifting (BEPS).

“Many BEPS techniques rely on abuse of tax treaties, and the OECD/G20 BEPS Project has recommended a number of changes to further strengthen tax treaties multilaterally,” Mr Woodhouse says.

“The OECD have proposed a multilateral instrument that will rapidly amend a worldwide network of several thousand bilateral tax treaties, rather than countries having to implement these amendments on a treaty-by-treaty basis.”

The instrument text is the result of work undertaken by the OECD and around 100 countries over the past year.

“New Zealand officials have been working with other countries and the OECD to develop this unique instrument, which will enable New Zealand to quickly and efficiently strengthen our tax treaties against BEPS techniques.

“BEPS is a global problem that this government is committed to addressing. The best way to do that is through a co-ordinated global response, which is why we are fully committed to the multilateral instrument.”

Officials will now begin consultation on the implementation of the multilateral instrument, with the signing expected to take place in June 2017.

The text of the multilateral instrument can be found at