This Explanatory Statement, adopted by the members of the ad hoc Group on 24 November 2016 together with the text of the Convention, clarifies how the Multilateral Convention implementing the tax treaty-related BEPS measures modifies Covered Tax Agreements. It sets out the approach taken in the Convention, including the listing of Covered Tax Agreements, reservations, notifications, compatibility clauses and optional provisions, then comments paragraph by paragraph on the Preamble and Articles 1 to 39 under Parts I to VII: scope and interpretation of terms, hybrid mismatches, treaty abuse, avoidance of permanent establishment status, improving dispute resolution, mandatory binding arbitration and final provisions.