The OECD has signed off on a number of amendments to the Model Tax Treaty. The changes are by no means fundamental, the more significant possibly being those concerning the definition of “beneficial owner” and some modifications to exchange of information arrangements. The relatively small scale of the changes, and the length of time it has taken to conclude on them underlines the difficulties of achieving international consensus on tax matters. No changes have been made arising from the BEPS project, although there is a suggestion that Article 5 on Permanent Establishment will change. This may be a bit previous.