Without explicitly naming the United States, Mr Hockey inferred that he was concerned that the Obama administration had taken too long to come to the table on the issue, and was now looking to protect its own tax base.

Most of the companies accused of not paying tax are headquartered in the United States. This has made it difficult for the OECD to get agreement from G20 governments on all elements of its Base Erosion and Profiting Shifting (BEPS) project.

In answer to questions at PwC's tax forum held in Melbourne on Wednesday, Mr Hockey said he wanted Australia to become more competitive globally, but it was important foreign-based multinationals paid their fair share of tax domestically.

"When I first became Treasurer and raised at the G20 the fact that multinationals were not paying their fair share of tax, a number of finance minister colleagues - well in fact just one or two - said, 'leave it alone, they're our companies.They pay their fair share of tax in our jurisdiction'.

"I must say that view has changed over past 12 months, and that country in particular has decided to not only go after the tax those companies owe in their jurisdiction, but they are trying to get the tax out of them that is owed in our jurisdiction as well. So there's been quite dramatic sea change in the G20 and across the OECD in the last 18 months."