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BEPS Action

OECD Guidelines

BEPS Action Plans

Base Erosion and Profit Shifting (BEPS) action plans and guidelines

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 solution.

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.

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.

Action 4
Limitation on Interest Deductions

Establishing rules that link an entity's net interest deductions to its level of economic activity within the jurisdiction.

Action 5
Harmful tax practices

Countering harmful tax practices with a focus on improving transparency.

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MINIMUM STANDARD
Action 6
Prevention of tax treaty abuse

Developing model tax treaty provisions and recommendations to prevent treaty abuse.

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MINIMUM STANDARD
Action 7
Permanent establishment status

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

Actions 8-10
Transfer pricing

Guidance for applying the arm's length principle.

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.

Action 12
Mandatory Disclosure Rules

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

Action 13
Country-by-Country Reporting

Improving tax transparency with country-by-country reporting.

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MINIMUM STANDARD
Action 14
Mutual Agreement Procedure

Making dispute resolution between jurisdictions more timely, effective and efficient.

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MINIMUM STANDARD
Action 15
Multilateral Instrument

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

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