Aggressive tax planning


  • Base Erosion and Profit Shifting

    Working Party No. 11 was formed in 2013 with responsibility under BEPS project for developing recommendations for Hybrid Mismatch Arrangements (Action 2), Controlled Foreign Companies (Action 3), Interest Deductibility (Action 4) and Mandatory Disclosure (Action 12).

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  • Co-operation and exchange of information on ATP

    The OECD provides a forum for countries to exchange information on tax planning schemes, detection methods and response strategies. The ATP Expert Group is a sub-group of Working Party No.11 that has responsability for maintaining a secure directory of over 400 aggressive tax planning schemes submitted by member countries.

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OECD's work on tax planning

Key dates

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OECD is at the forefront of efforts to improve international tax co-operation be‌tween governments to counter international tax avoidance and evasion. In furtherance of these goals the OECD set up the ATP Steering Group in 2004 to act as a centre of knowledge and expertise on international  tax planning. The Steering Group began with membership of 7 countries and has now grown to a full working party of 46 OECD and G20 countries. The OECD’s work focuses on identifying trends in international tax planning and helping governments to respond more quickly and effectively to emerging risks. The work is informed by a library of over 400 aggressive tax planning schemes stored on the OECD ATP Directory, a confidential database of schemes maintained by sub-group of countries that are members of WP11. 



Base erosion and profit shifting (BEPS) refers to tax planning strategies that exploit gaps in the architecture of the international tax system to artificially shift profits to places where there is little or no economic activity or taxation. The CFA has invited Working Party 11 (Aggressive Tax Planning), to carry out the work in relation to 4 of the items under the BEPS Action Plan.

These are:

  • Action 2 on Neutralising the Effects of Hybrid Mismatch Arrangements
  • Action 3 on Strengthening CFC rules
  • Action 4 on Limiting Base Erosion via Interest Deductions and Other Financial Payments.
  • Action 12 on Requiring Taxpayers to Disclose their Aggressive Tax Planning Arrangements.


The report on Action 2 was published in September 2014 and the reports on Actions 3, 4 and 12 are due to be published in September 2015.


5 October 2015
Launch of 2015 BEPS package


12 May 2015
Action 3 - Public consultation


11 May 2015
Action 12 - Public consultation


5 May 2015
Action 3 - Public Comments received on Action 3


4 May 2015
Action 12 - Public Comments received on Action 12


3 April 2015
Action 3 - Public release of discussion draft (deadline for comments: 1 May 2015)


31 March 2015
Action 12 - Public release of discussion draft (deadline for comments: 30 April 2015)



17 February 2015
Action 4 - Public consultation


11 February 2015
Action 4 - Public Comments received on Action 4


18 December 2014
Action 4 - Public release of discussion draft
















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