Resumen de BEPS: the issues of dispute resolution and introduction of a multilateral treaty
Any new international rule is liable to engender new disputes between States and/or States and citizens. Where a number of countries are concerned, dispute resolution is facilitated if mechanisms are provided in a multilateral treaty. So, why not embody the substantive rules themselves in such an instrument? There is a certain logic to dealing with these two problems simultaneously, insofar as they are raised by the Organization for Economic Cooperation and Development (OECD's) Base erosion and profit shifting (BEPS) Action Plan.
