ARTICLE · 02 DECEMBER 2015

The Implementation Of BEPS - How It May All Come Together

ENS

Explore more from ENS

The Final Report on Action 15 explores the feasibility of developing a multilateral instrument that would have the same effect as a simultaneous renegotiation of thousands of bilateral tax treaties.

South AfricaTax

Esther Geldenhuys

Author LinkedIn connections

We are all aware of "base erosion and profit shifting" or "BEPS". On 5 October 2015, the OECD released its final reports in connection with its BEPS Action Plan including its final report on Action 15 dealing with the development of a multilateral instrument to modify bilateral tax treaties ("Final Report"). The Final Report on Action 15 explores the feasibility of developing a multilateral instrument that would have the same effect as a simultaneous renegotiation of thousands of bilateral tax treaties.

Action 15, more specifically, addresses the need to implement the measures resulting from the work on the entire BEPS Action Plan and specifically those measures that would require amendments to the OECD Model Tax Convention and its Commentary as well as bilateral tax treaties. These measures include the following:

We operate a free-to-view policy, asking only that you register in order to read all of our content. Please login or register to view the rest of this article.

Register for freeORLog in

Related Articles

Africa Tax In Brief

South AfricaTax

ENS Tax In Brief

South AfricaTax

Deferral Of Payment Arrangements With SARS: What You Need To Know

South AfricaTax

SNG Grant Thornton

Debt Compromise: Can You Settle Your Tax Debt For Less?

South AfricaTax

SNG Grant Thornton

Provisional Tax Understatement Penalties: First-time Provisional Taxpayers

South AfricaTax

SNG Grant Thornton

Legal Intelligence Newsletters: sign up for the latest legal and regulatory news on your chosen topics

Read more about

Tax
- Tax Treaties

Related Comparative Guides

Comparative Guide

Tax Disputes

Comparative Guide

Tax

See more popular content from

Tax

Africa Tax In Brief

African nations are implementing sweeping tax reforms across multiple jurisdictions, from Angola's supplementary petroleum incentives and Nigeria's virtual asset taxation framework to Mauritius's digital marketplace VAT rules and the Democratic Republic of the Congo's mining royalty adjustments. These coordinated changes reflect a continent-wide effort to modernize revenue collection, expand digital taxation, and strengthen compliance mechanisms.

South AfricaTax

Africa Tax In Brief - 14 July 2026

This comprehensive update covers significant tax and regulatory developments across 30 African jurisdictions during mid-2026, including Angola's new oil block incentives and unified Personal Income Tax Code, Botswana's major tax rate increases and transfer pricing regulations, Kenya's Finance Act 2026 with mortgage interest relief expansion, Nigeria's implementation of the unified Taxpayer Identification system and presumptive tax regime, and Rwanda's new transfer pricing rules framework. The bulletin exami

Africa Tax In Brief

According to the OECD's Revenue Statistics in Africa 2025 report released in December 2025, tax revenues as a percentage of GDP have increased in 24 countries...

Extending Boundaries: Adjustments To South African Exchange Control Limits And Powers

The Financial Surveillance Department of the South African Reserve Bank (“FinSurv”) recently published a suite of draft exchange control circulars for comment, giving effect to the Minister of Finance’s 2026 Budget Speech announcements...

South AfricaTax

Frozen Accounts And Fraudulent Funds: Navigating The Rights Of Banks, Customers And SARS

A South African High Court has ruled on the lawfulness of account freezing by banks based on fraud suspicions and affirmed SARS's authority to issue third-party notices under section 179 of the Tax Administration Act. The case arose after a close corporation fraudulently claimed a VAT refund of R3.28 million, transferred R900,000 to an individual's account, prompting the bank to freeze the account and SARS to pursue recovery through a third-party notice.

South AfricaTax

Tax Landscape Mining

South Africa's mining sector operates in a complex tax, regulatory and ESG environment requiring careful management of specialist income tax rules, mineral royalties, VAT, customs obligations...

South AfricaTax

SNG Grant Thornton

Africa Tax In Brief

This comprehensive briefing covers recent tax law changes, regulatory updates, and compliance requirements across multiple African jurisdictions including Benin, Botswana, Burkina Faso, Burundi, and many others. The updates span corporate tax reforms, VAT amendments, withholding tax changes, and new administrative procedures affecting businesses operating throughout the continent.

Deferral Of Payment Arrangements With SARS: What You Need To Know

Struggling to pay your tax debt? SARS offers payment arrangements that allow taxpayers to settle outstanding liabilities through installments over 1 to 36 months. Understanding when and how to apply for these arrangements can help you avoid debt collection action while maintaining compliance with the South African Revenue Service.

South AfricaTax

SNG Grant Thornton

Trading Property For Shares: A Strategic Way To Move Assets Into A Company

Most property transactions follow a familiar script where a purchaser pays a purchase price, transfer duty may be triggered, and capital gains tax (CGT) is assessed at the point of disposal

South AfricaTax

Tax Law Tightens For SA Trusts With Offshore Beneficiaries

South Africa's recent amendment to section 25B of the Income Tax Act introduces a material change in the taxation of income distributed by resident trusts to non-resident beneficiaries.

South AfricaTax

Beach Weather | Legal Marketing