OECD highlights progress and burden reduction on BEPS standards

The OECD/G20 Inclusive Framework report endorsed practical adjustments to ease the BEPS minimum standards’ administrative burdens. 

RegFollower Desk

The OECD reported on 4 July 2025 that the members of the OECD/G20 Inclusive Framework has endorsed practical adjustments to reduce administrative burdens in implementing BEPS minimum standards. These recommendations were adopted at the April 2025 plenary meeting in Cape Town.

In 2013, the project on base erosion and profit shifting (BEPS) was launched. Since then, the BEPS Project has resulted in a major update to the international tax system by equipping governments with rules and instruments to ensure that profits are taxed where economic activities generating them take place and where value is created.

Today, more than 145 jurisdictions are members of the Inclusive Framework on BEPS (the “Inclusive Framework”), participating on an equal footing and working towards the development of a fair and sustainable global tax environment. A key function of the Inclusive Framework is to monitor progress and review the implementation of the four BEPS minimum standards that were identified as part of the 15-point BEPS Action Plan published in 2013 (OECD, 2013[1]). Acknowledging their interdependence in addressing BEPS-risks, Inclusive Framework jurisdictions commit to implement four BEPS minimum standards which cover Action 5 on Harmful Tax Practices, Action 6 on Tax Treaty Abuse, Action 13 on Country-by-Country Reporting, and Action 14 on Dispute Resolution.

Implementation of the four BEPS minimum standards has reached a mature stage, reflecting a strong commitment to address BEPS risks across the membership of the Inclusive Framework. In light of this, the focus of the work of the Inclusive Framework is now increasingly on making sure that all members – and in particular developing countries – can fully benefit from the four minimum standards. To support this objective, capacity building programmes and tailored technical assistance are being delivered to ensure the swift, efficient and sustainable implementation of the BEPS project in all interested Inclusive Framework member countries.

At the same time, attention has turned to reducing the burdens associated with the peer review processes, which have now been running for a number of years, and strengthening the overall value proposition of the minimum standards. This work was initiated at the May 2024 Plenary meeting of the Inclusive Framework in Paris and advanced further at the Working Party level.

As a result of this work, the Inclusive Framework, at its April 2025 Plenary meeting in Cape Town, adopted a series of recommendations to streamline the peer review processes for the BEPS minimum standards. It also endorsed the proposal to introduce targeted adjustments to optimise the allocation of resources among Inclusive Framework members, ensuring that efforts remain focused on areas of greatest impact, while preserving the effectiveness and integrity of the BEPS minimum standards. Particular attention has been given to strengthening the value proposition of the BEPS Project by identifying priority areas for enhanced support, particularly with a focus on improving access to Country-by-Country reports by developing countries.

This note summarises the outcomes of this work. It provides a brief overview of the current status of implementation of each of the four minimum standards, outlines agreed measures to reduce burdens, and highlights renewed priorities for the Inclusive Framework aimed at maintaining progress and futureproofing the value proposition of the BEPS Project, including by ensuring that all interested developing countries can fully benefit from the work. The revised peer review methodology for BEPS Action 5 on Harmful Tax Practices is included in the Annex to this report.

Looking ahead, the Inclusive Framework will continue to consolidate the progress achieved so far by optimising resource allocation within the Inclusive Framework Secretariat and enhancing the support for jurisdictions with limited resources. In addition, and as announced in the outcome statement of the Inclusive Framework Plenary meeting in Cape Town, work is ongoing to take stock of the BEPS work to date, with a comprehensive report expected to be presented in the last quarter of 2025.