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This interim report of the OECD/G20 Inclusive Framework on BEPS is a follow-up to the work delivered in 2015 under Action 1 of the BEPS Project on addressing the tax challenges of the digital economy. It sets out the Inclusive Framework’s agreed direction of work on digitalisation and the international tax rules through to 2020. It describes how digitalisation is also affecting other areas of the tax system, providing tax authorities with new tools that are translating into improvements in taxpayer services, improving the efficiency of tax collection and detecting tax evasion.

A key part of the OECD/G20 BEPS Project is addressing the tax challenges arising from the digitalisation of the economy. In October 2021, over 135 jurisdictions joined a ground-breaking plan to update key elements of the international tax system which is no longer fit for purpose in a globalised and digitalised economy. The Global Anti-Base Erosion Rules (GloBE) are a key component of this plan and ensure large multinational enterprise pay a minimum level of tax on the income arising in each of the jurisdictions where they operate. More specifically, the GloBE Rules provide for a co-ordinated system of taxation that imposes a top-up tax on profits arising in a jurisdiction whenever the effective tax rate, determined on a jurisdictional basis, is below the minimum rate. This Commentary to the GloBE Rules provides tax administrations and taxpayers with guidance on the interpretation and application of those rules in order to promote a consistent and common interpretation of the GloBE Rules that will facilitate coordinated outcomes for both tax administrations and MNE Groups. This Commentary explains the intended outcomes under the GloBE Rules and clarifies the meaning of certain terms. It also illustrates the application of the rules to certain fact patterns.

A key part of the OECD/G20 BEPS Project is addressing the tax challenges arising from the digitalisation of the economy. In October 2021, over 135 jurisdictions joined a ground-breaking plan to update key elements of the international tax system which is no longer fit for purpose in a globalised and digitalised economy. The Global Anti-Base Erosion (GloBE) Rules are a key component of this plan and ensure large multinational enterprise pay a minimum level of tax on the income arising in each of the jurisdictions where they operate. More specifically, the GloBE Rules provide for a co-ordinated system of taxation that imposes a top-up tax on profits arising in a jurisdiction whenever the effective tax rate, determined on a jurisdictional basis, is below the minimum rate. The Commentary to the GloBE Rules was originally released by the Inclusive Framework in March 2022. The Commentary explains the intended outcomes under the GloBE Rules, clarifies the meaning of certain terms and illustrates the application of the rules to certain fact patterns. This Consolidated Commentary incorporates Agreed Administrative Guidance that has been released by the Inclusive Framework since March 2022 up until December 2023. It provides tax administrations and taxpayers with guidance on the interpretation and application of the GloBE Rules in order to promote a consistent and common interpretation and application of those that will facilitate coordinated outcomes for both tax administrations and MNE Groups.

A key part of the OECD/G20 BEPS Project is addressing the tax challenges arising from the digitalisation of the economy. In October 2021, over 135 jurisdictions joined a ground-breaking plan – the Two-Pillar Solution to Address the Tax Challenges Arising from the Digitalisation of the Economy – to update key elements of the international tax system which is no longer fit for purpose in a globalised and digitalised economy. The Global anti-Base Erosion Rules and the Subject to Tax Rule (STTR) are key components of Pillar Two of this plan and ensure multinational enterprises pay a minimum level of tax on the income arising in each of the jurisdictions where they operate. More specifically, the STTR is a treaty-based rule that protects the right of developing Inclusive Framework members to tax certain intra-group payments, where these are subject to a nominal corporate income tax that is below the minimum rate. This report contains the model treaty provision to give effect to the STTR, together with an accompanying commentary explaining the purpose and operation of the STTR.

The Global Forum on Taxation, which consists of OECD and non-OECD economies, seeks to improve transparency and to establish effective exchange of information so that countries can ensure compliance with their national tax laws. The Global Forum is working towards a level playing field in these areas so that activities do not simply migrate from countries that engage in effective exchange of information to those that do not. In working towards a level playing field, the Global Forum seeks to ensure the implementation of high standards of transparency and information exchange in a way that is fair, equitable and permits fair competition between all countries, large and small, OECD and non-OECD.   This Report describes the key principles that guide the Global Forum's work and sets out the current status of the legal and administrative frameworks for transparency and exchange of information in over 80 economies.

In 2006, the Global Forum on Taxation, which includes both OECD and Non-OECD economies, launched an annual assessment of transparency and tax information exchange policies covering 82 economies.  This update report highlights changes made over the last year in the domestic laws and regulations of the 82 economies The report sets out in a series of tables - on a country by country basis - information on laws and agreements permitting exchange of information for tax purposes; access to bank information for tax purposes; access to ownership, identity and accounting information; and availability of ownership, identity and accounting information relating to companies, trusts, partnerships and foundations.

The OECD Global Forum on Taxation's annual assessment of transparency and tax information exchange policies in more than 80 economies. This report is the second edition of that assessment. It highlights changes made over the last year in the domestic laws and regulations of the economies covered by the 2007 Assessment. In addition to the countries reported on in 2007, it includes information on Chile, bringing to 83 the number of countries covered by the report. The report sets out in a series of tables, on a country by country basis, information on laws and agreements permitting the exchange of information for tax purposes; access to bank information for tax purposes; access to ownership identity and accounting information; and availability of ownership, identity and accounting information relating to companies, trusts, partnerships and foundations.

This fourth annual assessment of transparency and tax information policies carried out by the OECD Global Forum on Transparency and Exchange of Information brings to 87 the number of countries covered by the report.  Four new countries are covered in this edition: Estonia, India, Israel, and Slovenia. This edition also features for each country new summary assessments providing a snapshot of their legal and administrative framework. The report sets out on a series of tables, on a country-by-country basis, information on: laws and agreements permitting the exchange of information for tax purposes;  access to bank information for tax purposes;  access to ownership identity and accounting information; and availability of ownership, identity and accounting information relating to companies, trusts, partnerships and foundations.

This study introduces the concept of “Tax Compliance by design”. It describes how revenue bodies can exploit developments in technology and the ways in which modern SMEs organise themselves to incorporate tax compliance into the systems businesses use to manage their financial affairs.

This publication describes how enterprises are taxed on foreign exchange gains and losses resulting from currency fluctuations and analyses the consequences of differences in country practices.

Reports the results of a project examining taxation and foreign direct investment (FDI), with a focus on three areas.  Recent empirical studies and models are first reviewed, with the aim of better understanding what factors explain differences in the responsiveness of FDI to taxation, in different country and industry contexts.  Second, the publication reports an exchange of views on considerations that are balanced by tax policy makers in the design of rules governing the taxation of inbound and outbound FDI, including increasing pressure to provide “internationally competitive” tax treatment.  Third, the publication presents findings from a new framework developed for the project to analyse the implications of tax-planning by multinationals in reducing effective tax rates on cross-border investment.  The findings highlight the need to address tax-planning when attempting to measure the “true” tax burden on FDI.

In October 2021, the international community agreed a landmark deal on the two-pillar solution to the tax challenges arising from the digitalisation and the globalisation of the economy. As part of this plan, Pillar Two establishes a global minimum effective corporate tax rate of 15% for large multinational enterprises (MNEs) which has important implications for the use of tax incentives around the world. This report, prepared at the request of the Indonesian G20 Presidency, provides a number of concrete considerations for countries to take into account as they prepare for the implementation of Pillar Two. Wherever tax incentives drive an MNE’s effective tax rate (ETR) in a jurisdiction below 15%, the MNE would potentially be subject to top-up taxes under the GloBE Rules, a core component of Pillar Two. These rules may have an impact on the effectiveness of certain tax incentives. Therefore, the design of tax incentives will require careful reconsideration in a post-Pillar Two environment. The report considers the existing use of tax incentives in developed and developing countries, analyses key provisions of the GloBE Rules and shows how they may impact different types of tax incentives differently. The report concludes with policy considerations for countries.

Unlocking what drives tax morale – the intrinsic willingness to pay tax – can greatly assist governments in the design of tax policies and their administration, particularly in developing countries where compliance rates are low. This report builds on previous OECD research to identify some of the key socio-economic and institutional drivers of tax morale across developing countries, and seeks to test for evidence of the social contract by examining the impact of public services on tax morale. It also uses new data on tax certainty as an entry point to explore tax morale in businesses, where existing research is very limited. Finally, the report identifies a range of factors related to the tax system that may affect business decision making, how they vary across regions, and suggests some areas for future research. Overall, the report provides a range of suggestions for further work, and how tax morale considerations can be integrated into holistic tax compliance strategies.

The issue of trust between Multinational Enterprises (MNEs) and tax administrations is a vital part of the tax system, but relatively little studied. Building on previous OECD research on tax morale, which measures taxpayer perceptions and attitudes towards paying and evading taxes, this report presents new data on how tax administrations perceive MNE behaviour towards tax compliance. With a particular focus on the challenges facing developing countries, this report brings together this data with previous data on MNE perceptions, and the outcomes of a series of regional roundtables on tax morale held between tax administrations and MNEs. Having identified a number of challenges around trust, transparency and openness, the report sets out a range of approaches to help build trust, improve communications, and build more effective relationships between taxpayers and tax administrations.

This third edition covers the latest tax policy reforms in all OECD countries, as well as in Argentina, Indonesia and South Africa. Monitoring tax policy reforms and understanding the context in which they were undertaken is crucial to informing tax policy discussions and to supporting governments in the assessment and design of tax reforms.