On 5-6 November 2015, the OECD held the inaugural meeting for the negotiation of the Multilateral Instrument for the implementation of the treaty-related provisions developed as part of the BEPS Project. According to a release from the OECD, the ad-hoc group for the development of the instrument includes 94 members, including both OECD and non-OECD countries. A sub-group of approximately 25 members will also be formed to develop an optional provision on mandatory binding mutual agreement procedure (MAP) arbitration. Further negotiations will take place in 2016, with public consultations to be launched before the next meeting, which will likely be...