The multilateral proposed changes require significant infrastructural changes to the existing tax framework. How should such changes be implemented? Some changes are required at both the domestic law level and in the public international law arena of double taxation treaties. Other changes can be made in one or other of these fields of law (domestic or international). What other matters need to be addressed? There are many questions in the area of implementation, such as dispute resolution and dispute prevention, calculation and collection of tax, use of multilateral instruments, and the prevention of double taxation.