Multilateral Cooperation in Tax Law

S. 1041. Introduction

1.1. The BEPS Project and the BEPS Four Minimum Standards

In February 2013, the first OECD-study commissioned by the G20 on Base Erosion and Profit Shifting (BEPS) was published. Besides presenting the issues related to BEPS, a strong message was also sent, i.e. a clear need for international cooperation, transparency, and the adoption of a comprehensive and coordinated approach to international tax law supported at a global level. As a result, in September 2013, the OECD published a global BEPS Action Plan endorsed by the G20 consisting of fifteen actions that may be grouped into the following main themes: Addressing substance; coherence of the international tax system; transparency; address digital businesses; enhance dispute resolution; and develop a multilateral instrument. After two years of work, in October 2015, the OECD released 13 reports as final deliverables of the BEPS Action Plan (BEPS Reports). In 2016, the OECD presented an Inclusive Framework (IF) allowing non-OECD and non-G20 countries to participate on an equal footing in the BEPS Project with respect to the implementation of at least four BEPS Actions, considered to be minimum standards: i) BEPS Act...