This lesson examines the institutional framework established to implement and monitor BEPS measures, including the creation of the Inclusive Framework and the process of peer review for minimum standards.

• The Inclusive Framework on BEPS: Launched in 2016 following a call from the G20, the Inclusive Framework brings together over 145 jurisdictions on an equal footing in the OECD Committee on Fiscal Affairs. Its purpose is to ensure consistent and coordinated implementation of BEPS recommendations and to establish a level playing field. All members commit to implementing the four BEPS minimum standards and participate in peer reviews that monitor compliance and progress.

• The Four BEPS Minimum Standards: Implementation by all relevant jurisdictions is needed to avoid negative spillover effects across jurisdictions. Progress has been significant: Action 5 (Harmful Tax Practices) has seen over 300 preferential regimes examined, with almost all found to pose BEPS risks amended or abolished. Action 6 (Prevention of Treaty Abuse) has achieved over 95% compliance among Inclusive Framework members’ treaties. Action 13 (CbCR) has been enacted by 120 members, with nearly 100 jurisdictions exchanging data through approximately 4,650 bilateral relationships. Action 14 (MAP) has resulted in over 500 treaties being modified to include effective MAP provisions.

• The Multilateral Instrument (MLI): The MLI, adopted in 2016, enables the efficient implementation of tax-treaty-related BEPS recommendations into existing bilateral tax treaties without the need for each treaty to be renegotiated individually. It incorporates key anti-abuse measures, including the Principal Purpose Test (PPT) and/or Limitation on Benefits (LOB) provisions, depending on the options selected by signatory jurisdictions.