Base erosion and profit shifting

Transparency on tax rulings now the global norm, according to new peer review assessments for over 120 jurisdictions


15/12/2020 - As part of continuing efforts to improve tax transparency, the OECD/G20 Inclusive Framework on BEPS (Inclusive Framework) has reviewed the progress made by 124 jurisdictions in spontaneously exchanging information on tax rulings, in accordance with the BEPS Action 5 minimum standard. The conclusions show that transparency on tax rulings is now a fully-entrenched part of the international tax framework, with 20 000 tax rulings having been identified and 36 000 exchanges between jurisdictions having taken place.


According to the 2019 Peer Review Reports on the Exchange of Information on Tax Rulings released today, 81 jurisdictions are now fully in line with the BEPS Action 5 minimum standard, with the remaining 43 jurisdictions receiving one or more recommendations to improve their legal or operational framework to identify and exchange the tax rulings.


As the delivery of the BEPS Project has reached its five-year mark this year, the Inclusive Framework is now working to ensure that the progress made on ensuring transparency in relation to the issuance of tax rulings is maintained towards the future, both through a review of the overall effectiveness of the Standard and the development of a renewed peer review process for the years 2021 – 2025.


The full details of this year’s peer reviews and the outcomes can be accessed via



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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