Actions to Counter Base Erosion and Profit Shifting : A General Report

World events in the first decade of this century led many to question the state of the international tax regime and the role it could play in solving national fiscal problems. In 2012, leaders of the Group of 20 (G20) set the OECD an ambitious agenda of working out how tax base erosion and profit shifting could be addressed. The OECD responded with a BEPS (base erosion and profit shifting) plan including 15 distinct Actions. Following a decision by G20 leaders to extend the BEPS project to all countries, under the guidance of the OECD the project evolved into a blueprint for the reform of international tax regimes around the world. By October 2018, 118 jurisdictions had joined the BEPS Inclusive Framework, as the project was labelled. This chapter reviews the 15 Actions and summarises the 18 case studies included in this volume to show how jurisdictions are responding to the obligations set out in the Actions. The case studies indicate countries are taking two paths to combat international tax avoidance – multilateral cooperation through the BEPS program, along with its associated multilateral instrument, and unilateral moves through the adoption of new taxes imposed on multinational enterprises. It remains to be seen which approach will prevail in the long term and whether the multilateral path might someday lead to an international treaty on the allocation of multinational income