ACTiOn 14: 2015 Final Report
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OECD/G20 Ba Erosion and Profit Shifting Project万径人踪灭全诗
Making Dispute Resolution Mechanisms More Effective, Action 14
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Plea cite this publication as:
OECD (2015), Making Dispute Resolution Mechanisms More Effective, Action 14 - 2015 Final Report,头像女二次元
OECD/G20 Ba Erosion and Profit Shifting Project, OECD Publishing, Paris.
dx.doi/10.1787/9789264241633-en
ISBN 978-92-64-24158-9 (print)
ISBN 978-92-64-24163-3 (PDF)
Series: OECD/G20 Ba Erosion and Profit Shifting Project
ISSN 2313-2604 (print)
ISSN 2313-2612 (online)
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© OECD 2015
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F OREwORD – 3
Foreword
International tax issues have never been as high on the political agenda as they are today. The integration of national economies and markets has incread substantially in
recent years, putting a strain on the international tax rules, which were designed more than a
century ago. weakness in the current rules create opportunities for ba erosion and profit
shifting (BEPS), requiring bold moves by policy makers to restore confidence in the system
and ensure that profits are taxed where economic activities take place and value is created.
Following the relea of the report Addressing Ba Erosion and Profit Shifting in February 2013, OECD and G20 countries adopted a 15-point Action Plan to address
BEPS in September 2013. The Action Plan identified 15 actions along three key pillars:
introducing coherence in the domestic rules that affect cross-border activities, reinforcing
substance requirements in the existing international standards, and improving transparency
as well as certainty.
Since then, all G20 and OECD countries have worked on an equal footing and the European Commission also provided its views throughout the BEPS project. Developing
countries have been engaged extensively via a number of different mechanisms, including金字旁今
direct participation in the Committee on Fiscal Affairs. In addition, regional tax organisations
such as the African Tax Administration Forum, the Centre de rencontre des administrations
fiscales and the Centro Interamericano de Administraciones Tributarias, joined international
organisations such as the International Monetary Fund, the world Bank and the United
Nations, in contributing to the work. Stakeholders have been consulted at length: in total,
the BEPS project received more than 1 400 submissions from industry, advirs, NGOs and
academics. Fourteen public consultations were held, streamed live on line, as were webcasts
where the OECD Secretariat periodically updated the public and answered questions.
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After two years of work, the 15 actions have now been completed. All the different outputs, including tho delivered in an interim form in 2014, have been consolidated into
a comprehensive package. The BEPS package of measures reprents the first substantial
安神补脑口服液renovation of the international tax rules in almost a century. Once the new measures become
applicable, it is expected that profits will be reported where the economic activities that
generate them are carried out and where value is created. BEPS planning strategies that rely
on outdated rules or on poorly co-ordinated domestic measures will be rendered ineffective.
Implementation therefore becomes key at this stage. The BEPS package is designed to be implemented via changes in domestic law and practices, and via treaty provisions,
with negotiations for a multilateral instrument under way and expected to be finalid in
2016. OECD and G20 countries have also agreed to continue to work together to ensure a
consistent and co-ordinated implementation of the BEPS recommendations. Globalisation
requires that global solutions and a global dialogue be established which go beyond
OECD and G20 countries. To further this objective, in 2016 OECD and G20 countries will
conceive an inclusive framework for monitoring, with all interested countries participating
on an equal footing.
MAKING DISPUTE RESOLUTION MECHANISMS MORE EFFECTIVE © OECD 2015
