Base erosion and profit shifting

Over 130 jurisdictions comprehensively reviewed in the latest BEPS Action 5 peer review on tax rulings


14/12/2021 - Today, the OECD/G20 Inclusive Framework on BEPS is releasing the 2020 peer review assessments of 131 jurisdictions in relation to the spontaneous exchanges of information on tax rulings. The conclusions show that the global reach of the BEPS Action 5 minimum standard on tax rulings continues to increase, with 22 000 tax rulings having been identified and 41 000 exchanges between jurisdictions having taken place. The exchange on tax rulings is a critical tool in improving access of tax administrations to information relevant to assess the corporate tax affairs of their taxpayers and to efficiently tackle tax avoidance and other BEPS risks.


According to the 2020 Peer Review Reports on the Exchange of Information on Tax Rulings, 95 jurisdictions are now fully in line with the BEPS Action 5 minimum standard, with the remaining 36 jurisdictions receiving one or more recommendations to improve their legal or operational framework to identify and exchange the tax rulings. This is the first review taking place under the renewed peer review process, agreed by the Inclusive Framework last year, with a view to further enhancing and consolidating transparency in relation to the issuance of tax rulings.


The full details of the 2020 peer reviews and outcomes can be accessed via


More information on the BEPS Action 5 peer review and monitoring process.


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).



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