OECD updated BEPS Action 5 rules with new peer review terms and XML Schema for 2027.
The OECD released a set of revisions to the BEPS Action 5 minimum standard on the spontaneous exchange of information on tax rulings (the “transparency framework”) on 8 September 2025.
As part of its ongoing monitoring efforts, the OECD/G20 Inclusive Framework on BEPS has completed a review of the transparency framework’s effectiveness, in line with the mandate set out in the Revised BEPS Action 5 Transparency Framework on Tax Rulings.
This review has resulted in a number of changes to enhance the effectiveness of the standard, taking into account almost a decade of experience in exchanging information on tax rulings among Inclusive Framework members. The latest statistics show that over 58 000 information exchanges have taken place concerning more than 26 000 tax rulings that have been identified to date since the start of the BEPS Project.
Against this background, the report published, presents the outcomes of the effectiveness review of the transparency framework, including revised terms of reference, as well as a revised assessment methodology for peer reviews starting in 2026.
The report also sets out the revised Exchange on Tax Rulings (ETR) XML Schema and the related User Guide, reflecting the outcomes of the effectiveness review. The revised ETR XML Schema will support the spontaneous exchange on tax rulings under BEPS Action 5 from 1 January 2027.
