Base erosion and profit shifting

BEPS 2014 Deliverables


First recommendations for a co-ordinated international approach to combat tax avoidance by multinational enterprises


The BEPS Project aims to provide governments with clear international solutions for fighting corporate tax planning strategies that exploit gaps and loopholes of the current system to artificially shift profits to locations where they are subject to more favourable tax treatment.

The OECD work is based on a BEPS Action Plan endorsed by the G20 in July 2013, which identified 15 key areas to be addressed by 2015; with 7 actions to be delivered in September 2014. The September 2014 BEPS outputs were delivered in an interim form and, while agreed, were not finalised as they may be impacted by some of the decisions to be taken with respect to the 2015 Deliverables with which they interact. These 2014 outputs will be consolidated with the remaining 2015 deliverables to ensure a coherent package which will be delivered to the G20 Finance Ministers in October 2015, together with a plan for the follow-up work and a timetable for their implementation.


Explanatory Statement

Cover: BEPS 2014 Deliverables Explanatory Statement

This Explanatory Statement provides an overview of the seven BEPS reports delivered in 2014, which were arrived at through consensus of 44 countries on an equal footing (including all OECD members, OECD accession countries, and G20 countries) and extensive consultation of developing countries, business, NGOs and other stakeholders. It describes the context for the BEPS project and outlines the process for the work to date. It also describes the status of the 2014 reports in the context of the overall BEPS project, including remaining technical issues and potential interaction with the remaining BEPS work. Finally, it outlines the next steps for the BEPS work.

» Download the Explanatory Statement (EN / FR / ES)

Download the reports

Arrow Action 1 Action 1: Address the tax challenges of the digital economy (EN / FR / ES / KO / ZH)
Arrow Action 2 Action 2: Neutralising the Effects of Hybrid Mismatch Arrangements (EN / FR / DE / KO / ZH)
Arrow Action 5 Action 5: Countering Harmful Tax Practices More Effectively, Taking into Account Transparency and Substance (EN / FR / DE / KO / ZH)
Arrow Action 6 Action 6: Preventing the Granting of Treaty Benefits in Inappropriate Circumstances (EN / FR / KO / ZH)
Arrow Action 8 Action 8: Guidance on Transfer Pricing Aspects of Intangibles (EN / FR / KO / ZH)
Arrow Action 13 Action 13: Guidance on Transfer Pricing Documentation and Country-by-Country Reporting (EN / FR / DE / ES / KO / ZH)
Arrow Action 15

Action 15: Developing a Multilateral Instrument to Modify Bilateral Tax Treaties (EN / FR / KO / ZH)



Image: BEPS Webcast September 2014‌‌

Globalisation has offered multinational enterprises ever-increasing opportunities to reduce their taxes, often by moving profits to offshore financial centres. The OECD/G20 BEPS Project aims to provide governments the building blocks for a clear international solution to corporate tax planning strategies that exploit loopholes in the current legal framework.


Senior members from the OECD's Centre for Tax Policy and Administration (CTPA)  discussed the details of the first set of BEPS deliverables, the involvement of developing countries, the input from stakeholders, as well as the planned next steps.

» Watch

Press conference

Further reading

» OECD and G20 work on taxation

» BEPS Package


» View photos from the launch (Flickr)





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