Base erosion and profit shifting

OECD releases BEPS Action 14 reports for Austria, France, Germany, Italy, Liechtenstein, Luxembourg and Sweden


09/04/2020 - The work on BEPS Action 14 continues with today's publication of the stage 2 peer review monitoring reports of the seven jurisdictions in batch 2: Austria, France (also available in French), Germany, Italy, Liechtenstein, Luxembourg (also available in French) and Sweden


These reports evaluate the progress made by these seven jurisdictions in implementing any recommendations resulting from jurisdictions' stage 1 peer review reports. The stage 2 monitoring takes into account any developments in the period 1 April 2017 – 30 September 2018 and the MAP statistics are based on years 2016 and 2017.


The results from the peer review and peer monitoring process demonstrate positive changes across all seven jurisdictions, although not all show the same level of progress. Highlights include:

  • The Multilateral Instrument was signed by all seven jurisdictions and has already been ratified by five of them which brings a substantial number of their treaties in line with the standard. In addition there are bilateral negotiations either ongoing or concluded.
  • All jurisdictions now have a documented notification/bilateral consultation process to be applied in cases where an objection is considered as being not justified by their competent authority.
  • Austria, Germany, Italy, Luxembourg and Sweden have added more personnel to the competent authority function and/or made or initiated several organisational improvements (e.g. more face-to-face meetings between competent authorities) with a view to handle MAP cases in a more timely, effective and efficient manner.
  • Austria, Germany and Sweden decreased the amount of time needed to close MAP cases and Liechtenstein and Luxembourg met the sought-after 24-month average timeframe to close MAP cases.
  • Austria introduced legislative changes to ensure that all MAP agreements can be implemented notwithstanding domestic time limits if the treaty does not provide for it, while in five of the other six this is already the case.
  • Austria, Germany, Luxembourg and Sweden have updated or clarified issues in their MAP guidance.


Further progress on making dispute resolutions more timely, effective and efficient will become known as other stage 2 monitoring reports are published. In the meantime, the OECD will continue to publish stage 1 peer review reports in accordance with the Action 14 peer review assessment schedule. The publication of the ninth batch of Action 14 peer reviews is forthcoming.



Media queries should be directed to Pascal Saint-Amans, Director of the OECD Centre for Tax Policy and Administration (+33 1 45 24 91 08), or Achim Pross, Head of the International Co-operation and Tax Administration Division (+33 1 45 24 98 92).



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