Base erosion and profit shifting

OECD releases BEPS peer review reports on improving tax dispute resolution mechanisms and preventing treaty shopping


14/02/2019 - Progress continues with the implementation of the BEPS package, as the OECD releases additional peer review reports assessing countries’ efforts to implement the Action 6 and Action 14 minimum standards as agreed under the OECD/G20 BEPS Project. 




The first peer review report on the implementation of the Action 6 minimum standard on treaty shopping reveals that a large majority of Inclusive Framework members have begun to translate their commitment on treaty shopping into actions and are now in the process of modifying their treaty network.


The report includes the aggregate results of the peer review and data on tax treaties concluded by each of the 116 jurisdictions that were members of the BEPS Inclusive Framework on 30 June 2018. The report recognises the substantial progress that jurisdictions have made in 2017 and 2018 towards the implementation of the minimum standard.


The results of the peer review show the effectiveness of the multilateral instrument (MLI) in implementing the treaty-related BEPS measures. It is by far the preferred tool of Inclusive Framework members for implementing the minimum standard.





Also released today, the reports of Estonia, Greece, Hungary, Iceland, Romania, Slovak Republic, Slovenia and Turkey published today contain over 200 specific recommendations that will be followed up in stage 2 of the peer review process. The peer review reports incorporate MAP statistics from 2016 and 2017, as reported under the MAP Statistics Reporting Framework.


These stage 1 peer review reports continue to demonstrate that countries remain dedicated to turning the political commitments made by members of the OECD/G20 Inclusive Framework on BEPS into measureable, tangible progress. Countries from previous batches are already working to address deficiencies identified in their respective peer review reports. The OECD will continue to publish stage 1 peer review reports in accordance with the Action 14 peer review assessment schedule, and the first round of stage 2 reports will be published in the coming months. In total, 37 peer reviews have been finalised. The seventh batch of Action 14 peer reviews is already underway for eight more countries.



Media queries should be directed to Pascal Saint-Amans, Director of the OECD Centre for Tax Policy and Administration (+33 1 45 24 91 08), or Achim Pross, Head of the International Co-operation and Tax Administration Division (+33 1 45 24 98 92) or Jeffrey Van Hove, Head of the Tax Treaty, Transfer Pricing & Financial Transactions Division (+33 1 85 55 49 71)..


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