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.
- Policy Brief 1/2021: Reforming GST for a Global Digital Economy (PDF File 1MB)
- Policy Brief 2/2021: Hybrid Mismatches (PDF File 612KB)
- Policy Brief 3/2021: Controlled Foreign Companies (PDF File 510KB)
- Policy Brief 4/2021: Limitations on Interest Deductions (PDF File 1.2MB)
- Policy Brief 5/2021: Harmful Tax Practices (PDF File 639KB)
- Policy Brief 6/2021: Prevention of Treaty Abuse (PDF File 626KB)
- Policy Brief 7/2021: Permanent Establishment Status (PDF File 743KB)
- Policy Brief 8/2021: Transfer Pricing
- Policy Brief 9/2021: Country-by-Country Reporting (PDF File 527KB)
- Policy Brief 10/2021: Mandatory Disclosure Rules
- Policy Brief 11/2021: Mutual Agreement Procedure (PDF File 690KB)
- Policy Brief 12/2021: International Dispute Resolution: Arbitration (PDF File 787KB)
- Policy Brief 13/2021: Multilateral Instrument (PDF File 732KB)
- Policy Brief 14/2021: Global Forum (PDF File 844KB)
- Policy Brief 15/2021: Measuring and Monitoring BEPS (PDF File 686KB)
- Policy Brief 16/2021: Inclusive Framework Pillar One
- Policy Brief 17/2021: Inclusive Framework Pillar Two
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.