International Tax Design for
the 21st Century

A new era of international tax design began with the G20/OECD Base Erosion and Profit Shifting (BEPS) project in 2013. The BEPS project initiated a 15-point Action Plan to update century-old international tax rules to ensure effective taxation in the global digital economy.

This Policy Brief series explains in accessible language the 15 BEPS Actions and the global response to them over the last decade, identifies the impact, limitations and challenges for these reforms and looks forward to next steps in international tax design.

The Policy Brief series was launched at a webinar on Evaluating BEPS and Looking to the Future, 2-3 December 2021.

The 15-point BEPS Actions Plan aimed to update tax systems for the global digital economy (Action 1); improve cohesion in international tax rules (Action 2 to 5); restore substance (Actions 6 to 10); improve transparency and administration (Actions 11 to 14); and implement these changes in a new multilateral tax treaty (Action 15). It has generated a significant policy, law reform and administrative response from G20 and OECD countries, and has been adopted, to varying degrees, by an increasing number of countries around the world.

In 2021, the Inclusive Framework on BEPS agreed a Two-Pillar approach to taxing large multinational enterprises. Pillar One aims to establish a new taxing right for market jurisdictions of the largest and most profitable multinational enterprises. Pillar Two aims to coordinate reforms in participating countries for a minimum global effective tax of 15% on multinational enterprises.

Evaluating BEPS and Looking to the Future

This Policy Brief series on International Tax Design for the 21st Century is prepared by the Tax Group at the Melbourne Law School and is hosted by the Melbourne School of Government in its Regulation and Design research stream and by the Tax and Transfer Policy Institute at the Australian National University.