This report was produced by the Tax Policy and Statistics Division of the OECD’s Centre for Tax Policy and Administration. It was led by Daniel Fichmann under the supervision of Bert Brys, and written jointly by Daniel Fichmann, Felix Estgen, Yunis Griebenow, Melanie Marten, Patrice Ollivaud (Economics Department), Melina Rocha, and Ruairi Sugrue. The authors would like to thank the delegates of Working Party No.2 on Tax Policy Analysis and Tax Statistics in its Inclusive Framework format and the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting (BEPS) for their inputs, as well as colleagues Piet Battiau, Assia Elgouacem, Pierce O’Reilly, Sarah Perret, Anasuya Raj, and Kurt Van Dender (Head of the Tax Policy and Statistics Division) for their contributions and comments. The authors would also like to thank Karena Garnier for her assistance with editing and Michael Sharratt for his support with data processing.
The report was approved by the OECD/G20 Inclusive Framework on BEPS on 29 July 2026 and prepared for publication by the OECD Secretariat.