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 proc…