The BEPS Action 5 minimum standard includes the standard on the spontaneous exchange of information on tax rulings (the “transparency framework”). As part of its ongoing monitoring efforts, the Inclusive Framework 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. The first part of this report contains the outcomes of that review, including an overview of the revisions to the transparency framework. In addition, the report contains revised terms of reference applicable from the 2025 review year, as well as the revised assessment methodology for peer reviews starting in 2026. The second part of the report sets out the revised Exchange on Tax Rulings (ETR) XML Schema and the related User Guide, which reflect consequential technical changes in light of the effectiveness review. The revised ETR XML Schema will be used for all exchanges from 1 January 2027.
