Base Erosion and Profit Shifting (BEPS) Action Plan
Minimum standards for parts of the international tax system were agreed under the base erosion and profit shifting (BEPS) Action Plan as part of recommendations published in October 2015. The BEPS Inclusive Framework (IF) comprises around 130 countries committed to implementing those minimum standards – see the list of IF members on the OECD website (PDF)Opens in a new window. Alongside the minimum standards, which applied to elements of four of the fifteen action items, there were identified a number of best practices and areas for greater alignment.
Work stemming from the BEPS Action Plan
- Further BEPS work
- Tax Platform toolkits
- Implementation of minimum standards (for all IF countries)
- Other significant issues
Further BEPS work
- IF countries are participating on an equal footing in follow-up work to the BEPS Action Plan, including financial transactions
- The Action 1 recommendations have grown into a much broader project on the taxation of the digitalisation of the economy, on which extensive work is being carried out
The BEPS Project had been initiated by the G20 countries but it effectively also encompassed the other OECD Member States from the outset. As the project progressed, engagement in the discussions was extended to other large non-OECD states and representatives of developing countries. PwC submitted a large number of responses in relation to the various BEPS proposals put forward action by action. The OECD published over 1600 pages in the ‘final’ reports in relation to all 15 BEPS Action items in October 2015Opens in a new window and the wider range of IF countries became individually involved.
BEPS Action Plan: Action 1 - The digital economy |
BEPS Action Plan: Action 2 - Hybrid mismatch arrangements |
BEPS Action Plan: Action 3 - Controlled foreign companies (CFC) regimes |
BEPS Action Plan: Action 4 - Financial payments |
BEPS Action Plan: Action 5 - Harmful tax practices |
BEPS Action Plan: Action 6 -
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BEPS Action Plan: Action 7 - Permanent establishment (PE) status |
BEPS Action Plan: Action 8 - Transfer pricing and intangibles |
BEPS Action Plan: Action 9 - Transfer pricing and risks/ capital |
BEPS Action Plan: Action 10 - Transfer pricing and other high-risk transactions |
BEPS Action Plan: Action 11 - Data and methodologies |
BEPS Action Plan: Action 12 - Disclosure of aggressive tax planning |
BEPS Action Plan: Action 13 - Transfer pricing documentation |
BEPS Action Plan: Action 14 - Dispute resolution mechanisms |
BEPS Action Plan: Action 15 - A multilateral instrument |
It may take some while for the impact of these recommendations to be fully applied in practice, but the BEPS Project and related developments are constantly leading to the need for business to take action (in some cases, urgent action) both to comply with new requirements and to consider the ways in which they do business in different countries.
Latest key comments on BEPS
24 results
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Response to the OECD on MTC Article 9 consultation document
OECD publishes 2016 aggregated country-by-country report data as part of corporate tax statistics update
Unexpected taxing rights may result from changes to PE threshold aimed at artificial fragmentation
The OECD BEPS project recommended that the presence of a permanent establishment (PE) required under most double tax treaties to give taxing rights to a host country should be determined by taking into account certain activities in that country of related businesses.
OECD issues final paper on the transfer pricing aspects of financial transactions
The OECD on February 11 issued its final paper on the transfer pricing aspects of financial transactions (the OECD FT Paper), which will become Chapter X of the OECD Guidelines.
OECD findings on the economic analysis of Pillar One and Two
Governments, businesses, and civil society have long sought analysis of the potential economic and revenue effects of the Pillar One and Pillar Two proposals.
OECD consults on country-by-country reporting to tax authorities
The OECD published a consultation document Review of Country-by-Country Reporting (BEPS Action 13) on 6 February 2020 and launched a public consultation that will end on 6 March 2020, to be followed by a public hearing on 17 March 2020.
OECD G20 Inclusive Framework moves forward on new tax rules
The Inclusive Framework – comprised of nearly 140 jurisdictions – has been seeking a solution to the tax challenges arising from digitalisation of the economy.
OECD Pillar 2 Paper PwC Response December 2019
PwC International Ltd on behalf of its network of member firms (“PwC”) welcomes the opportunity to share its views in reaction to the OECD Secretariat’s Consultation Document (“CD”) on Pillar Two of the Work Programme on the Tax Challenges of the Digitalisation of the Economy (together with Pillar One, “the Project”).
Response to the OECD on the "Unified Approach" under Pillar 1 on Digitalisation
PwC International Ltd (PwC) welcomes the opportunity to share its views in reaction to the OECD secretariat’s consultation paper on the unified approach under Pillar 1 of the Work Programme on the Tax Challenges of the Digitalisation of the Economy.
Response to Tax Platform draft toolkit on Transfer Pricing Documentation
PwC’s Comments on the Draft Toolkit designed to help developing countries with the implementation of transfer pricing documentation requirements
OECD Secretariat seeks input on global minimum tax design
The Organisation for Economic Co-operation and Development (OECD) Secretariat on 8 November, published Public consultation document: Global Anti-Base Erosion Proposal (‘GloBE’) (Pillar Two) (‘the Consultation’) which seeks stakeholders’ views on the introduction of common global minimum tax rules across the more than...
OECD publishes proposal to rewrite international profit allocation rules
On 9 October, the Secretariat of the Organisation for Economic Co-operation and Development (OECD) published Secretariat Proposal for a “Unified Approach” under Pillar One (the “Pillar 1 Unified Approach”) that, if ultimately agreed, would fundamentally alter the international tax regime.
Work programme for reaching consensus on tax challenges from digitalisation sets ambitious targets according to stakeholders
If I comply with BEPS, am I prepared for DAC6 too?
The OECD’s Base Erosion and Profit Shifting (BEPS) initiative and the EU's cross-border tax arrangements directive, DAC6, both strive for transparency, fairness and integrity in the global tax ecosystem. However, they differ significantly from each other especially when it comes to reporting and sanctions. Watch here...
Tax Morale PwC response
Public Consultation Document: What is Driving Tax Morale?
Tax Challenges of the Digitalisation of the Economy - PwC Response
PwC response to OECD consultation on digital March 2019.
Response to EC consultation on administrative cooperation in direct taxation (2019)
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DAC6: The EU Directive on cross-border tax arrangements
The EU Council Directive 2011/16 in relation to cross-border tax arrangements, known as DAC6, has been in force since 25 June 2018. DAC6 aims for transparency.
Ep. 39: Transfer pricing compliance - A look at TP documentation and CbC reporting
Hear transfer pricing partners discuss the current state of country-by-country reporting as well as documentation.
OECD consultation to reshape the international tax system for the digitalised age commences
OECD Policy Note scopes work on the future of the international taxation system
DAC6 – EC’s feedback on the questions raised by Member States
PwC’s Comments on the non-consensus public Discussion Draft - “BEPS Actions 8 - 10 - Financial transactions”: 5 September 2018
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Contact us
Edwin Visser
Deputy Global Tax Policy Leader, EMEA Tax Policy Leader, PwC Netherlands
Tel: +31 88 792 3611
