Mr. Philip Kermode:

That is an interesting question. One of the work streams within BEPS is how the outcomes might or might not be implemented at the end of the day. At present, the technical work is taking place at OECD level and when this is completed the OECD will report back to the G20 on the outcomes. I understand transfer pricing and country by country reporting will be reported next January or February. The next question after this is how the compromise will be implemented around the world. Two outcomes are being discussed. The first is implementation by way of free negotiation of bilateral agreements and double tax agreements between countries. This would take a huge amount of time over a long period given that more than 200 countries are involved in 3,000 or 4,000 negotiations. A concept within BEPS is to examine a multilateral instrument which, by all countries signing it, would amend all bilateral agreements in one go. A recent OECD report went no further than stating it feels that such an instrument is feasible. A report on such an instrument will be issued in September as a way of moving forward the decision-making process. The question of how it will be implemented is embedded in the BEPS process itself.