Base erosion and profit shifting

OECD releases second peer review report on preventing treaty shopping (BEPS Action 6)


24/03/2020 - Progress continues with the implementation of the BEPS package, as the OECD releases the second peer review assessing countries’ efforts to implement the Action 6 minimum standard as agreed under the OECD/G20 BEPS Project. 


The second peer review report (also available in French) on the implementation of the Action 6 minimum standard on treaty shopping reveals that a large majority of members of the OECD/G20 Inclusive Framework on BEPS (IF) are translating their commitment on treaty shopping into actions and are modifying their treaty network.


The report includes the aggregate results of the peer review and data on tax treaties concluded by each of the 129 jurisdictions that were IF members on 30 June 2019. The report recognises the substantial progress that jurisdictions have made towards the implementation of the minimum standard.


The results of the peer review show that the MLI has been the tool used by the vast majority of jurisdictions that have begun to implement the minimum standard. The MLI’s impact is expected to increase quickly as jurisdictions ratify it and its coverage is also expected to increase as other jurisdictions with a large network of tax treaties are considering joining it.



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 Matt Andrew, Head of the Tax Treaty and Transfer Pricing Division (+33 1 85 55 45 78).


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