BEPS Actions

Developed in the context of the OECD/G20 BEPS Project, the 15 actions set out below equip governments with domestic and international rules and instruments to address tax avoidance, ensuring that profits are taxed where economic activities generating the profits are performed and where value is created.

Action 1

Tax Challenges Arising from Digitalisation

Dealing with the large range of tax challenges arising from the digitalisation of the economy to develop a consensus-based solutin by 2021. Read More

Action 2

Neutralising the effects of hybrid mismatch arrangements

Preventing hybrid mismatch arrangements from being used for BEPS while minimising impact on cross-border trade and investment.
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Action 3

Controlled Foreign Company

Reducing the incentive of taxpayers to shift income from a market country into foreign subsidiaries in a low-tax jurisdiction.
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Action 4

Limitation on Interest Deductions

Establishing rules that link an entity's net interest deductions to its level of economic activity within the juridistion
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Action 5

Harmful tax practices

Countering harmful tax practices with a focus on improving transparency
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Action 6

Prevention of tax treaty abuse

Developing model tax treaty provisions and recommendations to prevent treaty abuse
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Action 7

Permanent establishment status

Preventing artificial avoidance of permanent establishment status in tax treaties through commissionaire structures and more.
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Action 8-10

Transfer Pricing

Guidance for applying the arm's length principle
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Action 11

BEPS data analysis

Collecting and analysing data on the economic and fiscal effects of tax avoidance behaviours and on the impact of measures proposed under the BEPS Project.
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Action 12

Mandatory Disclosure Rules

Requiring taxpayers and advisors to disclose aggressive tax planning arrangements to tax authorities.
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Action 13

Country-by-Country Reporting

Improving tax transparency with country-by-country reporting
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Action 14

Mutual Agreement Procedure

Making dispute resolution between jurisdictions more timely, effective and efficient
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Action 15

Multilateral Instrument

Implementing the tax treaty-related BEPS recommendations to address vulnerabilities in existing tax treaties.
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